Universities are currently educating some 100,000 future and current healthcare professionals – from nursing associates in Cornwall to midwives in the Highlands, podiatrists in Belfast to radiographers in the Welsh valleys. All these students are studying on programmes which have been robustly approved and validated by healthcare regulators and which lead to qualifications that will allow them to join a professional register.
Healthcare professional education is rightly regulated by bodies which set standards including for programmes, supervision, and proficiencies. These are all necessary functions of professional regulators. However, could the current system be improved for the benefit of the public and students? And, what is the healthcare higher education sector’s views on the future of this system? The recent publication of two key documents – the UK Government’s Regulating healthcare professionals, protecting the public consultation and the Integration and Innovation white paper - provide an opportunity for us to reflect on the need for regulatory reform. Some key themes are emerging:
1. Outcome-focused regulation.
Healthcare higher education is in danger of burdensome and duplicative regulation from both healthcare professional and education regulators.[1] In recent years this regulation has become more complex with an increasing number of regulatory and quality bodies inspecting institutions. In England, a new higher education regulator, the Office for Students, has come onto the scene. Ofsted, the Institute for Apprenticeships and Technical Education (IfATE), and the Education and Skills Funding Agency (ESFA) now all engage in regulatory and quality interventions for healthcare apprenticeships. Too often higher education regulation impinges unnecessarily on healthcare professional regulation. Instead, regulation should be risk-based and outcome-focused.
2. Opportunities for innovation.
The pandemic has accelerated changes to healthcare delivery that were only expected to take place across the course of this decade. We need to consider the learning during this time from the higher education sector and NHS for the future of healthcare education.
Universities introduced extensive use of online learning to conform with social distancing guidelines. Virtual patient consultations were a great way for vulnerable students to access practice settings. Immersive technologies have also enabled the development of simulated practice placements, which can be used to rehearse and develop skills and behaviours. We welcome the Nursing and Midwifery Council’s (NMC) new recovery standard to increase simulation by an additional 300 hours.[2] Regulation must continue to be agile as we come out of the pandemic and should not be a barrier for the future integration of technological developments into healthcare education.
We also need to consider the opportunity that Brexit provides for reform to nursing and midwifery education. Any change to the EU Directive must of course assure public protection from both a regulatory and educational perspective. However, we now have an opportunity to move to a more fully competency-based rather than hours-based requirement in nursing and midwifery education within the continued context of degree-level programmes. Flexibilities to increase the use of simulation and digital technology for both theory and practice hours should be explored further.
3. Charging for quality assurance.
The UK Government’s current consultation proposes that the higher education sector could be charged for quality assurance activity. This is something that the sector strongly opposes. Healthcare professional education is already high-cost, resource intensive and relies on public subsidy to supplement student tuition fees in England.
Universities are already charged for quality assurance by higher education regulators across their provision. Charging institutions for quality assurance activities in healthcare subjects may have unintended consequences, such as causing some institutions to rethink existing provision, including in vulnerable disciplines. This would be problematic for the Government’s ambitious workforce growth targets.
Education is not supplementary to the key regulatory functions of healthcare professional regulators, but at its core and a crucial first part in the fitness to practise (FtP) function of any healthcare regulator. Education should not be viewed as an additional activity and source of funding for other regulatory activities.
Instead, we urge Government and regulators to look at options to reduce the high costs of registrant FtP activities. For example, in 2019/20 the NMC spent £37.9 million on FtP (46% of its expenditure).[3] Not even 1% of its registrants are referred annually and only 10% of these referrals lead to a hearing. Value for money is more likely to be found through reducing the cost of FtP processes than introducing fees for educational quality assurance.
The healthcare higher education sector is fortunate to benefit from positive and collaborative relationships with our regulators. The strength of these partnerships has been highlighted during the pandemic, as we have worked together to deploy thousands of students to support the NHS and continued to enable learners to progress and graduate to join the workforce. We look forward to working with regulators in future years to continue to ensure regulation is agile and meets the needs of the public, students, and educators.
Josh Niderost is Senior Policy and Public Affairs Officer at the Council of Deans of Health. The Council of Deans of Health represents the UK’s university faculties engaged in education and research for nurses, midwives, and allied health professionals.
Our first look at Government proposals to reform professional regulation, Let's get it right for public protection, can be read here.