General comments
We are pleased to have the opportunity to respond to the Health and Care Professions Council (HCPC) consultation on the HCPC standards of conduct, performance and ethics.
While our respective remits are different, we have a shared interest in supporting health and care professionals and services to provide the safest possible care.
We support the regular review of the standards of conduct, performance, and ethics to ensure that they remain relevant and respond to the health and social care operating context. We particularly welcome the commitments to equality, diversity, and inclusion and challenging discrimination in health and care settings.
We also welcome a more joined-up approach to developing standards across health and care professional regulators so there are shared approaches to ethics and behavioural standards across professional regulators. This is something employers want from regulation going forward.
Consultation questions
Q1. Do the revised Standards make it clear what the appropriate boundaries are between a registrant and service users or carers?
A. We support the core purpose of the Standards and the direction they set for registrants. We particularly welcome the HCPC’s commitment to developing Standards with clearer and active requirements around equality, diversity, and inclusion and challenging discrimination. We have a shared interest in supporting health and care professionals and services to provide the safest possible care. We look forward to working with the HCPC further as you develop these Standards and associated activities.
Q2. Do the revised Standards support registrants in maintaining their own well-being?
A. It might be useful for the Standards to make more explicit reference to maintaining the registrant’s own well-being. We have a shared interest in ensuring health and care professionals are supported to stay healthy at work and strive for our members to promote physical, emotional, and mental wellbeing at work.
Q3. Do the revised Standards ensure that registrants maintain a practice that promotes equal, fair, and inclusive treatment?
A. We support the emphasis in the revised Standards on ensuring equal, fair, and inclusive treatment.
Q4. Are the revised Standards clear about what registrants must do when things go wrong?
A. We support the emphasis in the revised Standards on professional responsibility to be open and honest with patients and families when something goes wrong.
Q5. Is the language used in the revised Standards accessible and clear?
A. We welcome the HCPC’s intention to ensure the revised Standards are accessible and clear. We are not aware (and do not have the evidence to determine) the accessibility of the revised Standards. We would be interested to know what work the HCPC has done or plans to do to evaluate the accessibility and clarity of the Standards.
Q6. Does the structure of the revised Standards promote understanding and easy reading?
A. We welcome the HCPC’s intention to ensure the revised Standards are structured to promote understanding. We are not aware (and do not have the evidence to determine) the effectiveness of the structure of the revised Standards. We would be interested to know what work the HCPC has done or plans to do to evaluate the structure of the Standards.
Q7. Are the revised Standards clear about the appropriate use of social media and how this relates to registrant practice?
A. Most employers in the NHS have organisational polices on the use of social media, intended to provide clarity on the expectation of staff and making staff aware of the potential risks associated with social media activity. The HCPC revised Standards on the use of social media appear to align with the approach taken by NHS organisations; staff who use social media are required to exercise proper judgement, act professionally and consider the appropriateness for any information or image they post. It might be useful for the Standards to make more explicit reference to these being observed by registrants when using social media in both a personal and professional capacity.
Q8. Should improving sustainability in heath and care practice be a part of the Standards?
A. Yes. We believe it would be worthwhile considering if there is a place in the Standards of conduct and ethics (across professional regulators) to encourage registrants to adopt more sustainable behaviours.
Q9. Do you consider there are any aspects of our proposals that could result in equality and diversity implications for groups or individuals based on one or more of the protected characteristics?
A. We are not aware (and do not have the evidence to determine) how the revised Standards may impact on people with protected characteristics. We would be interested to know what work the HCPC has done or plans to do to evaluate any potential impact of the Standards on people with protected characteristics. We are pleased to see the prominence the HCPC has placed on equality, diversity, and inclusion and challenging discrimination in health and care settings. On a related note, we are aware that there is some evidence suggesting unequal experiences of the professional regulatory processes associated with different protected characteristics and look forward to learning more about the HCPC’s future work in relation to EDI, and making registration better and fairer across professional regulators.
Q10. Do you have additional comments about any of the proposed changes to the Standards, or regarding the Standards of conduct, performance and ethics in general?
A. We welcome the HCPC’s commitment to engaging with other professional regulators during the consultation period of the Standards – we would be keen to see more of this approach. A joined-up approach to developing standards across health and care professional regulators so there are shared approaches to ethics and behavioural standards across statutory professional regulators is something employers want from regulation going forward.
