We concluded that the HCPC did not meet Standards 3, 15, 16, 17 and 18 of the Standards of Good Regulation.
General Standards: understands the diversity of its registrants, their service users and others who interact with it
The HCPC has been working to improve the level of EDI data it collects. It established an external EDI forum and engaged with members of the forum to develop its 2021-26 EDI strategy. However, we found that the HCPC did not have enough information about its registrants in respect of their protected characteristics. The HCPC also does not routinely seek such information about patients, service users and others. The HCPC did not meet Standard 3 as a result. The HCPC has continued to build on its EDI work and is continuing to collect data to develop its understanding of the diversity of those who interact with it, and we welcome these developments.
Guidance and Standards: provides guidance to help registrants and ensure this guidance is up to date
The HCPC published guidance to assist registrants meet the Standards of Conduct, Performance and Ethics (SCPE) during the Covid-19 pandemic. It published a series of stories from registrants who talked about their experience of working during the pandemic and also developed wellbeing resources and guidance for employers and students.
Registration: maintains an accurate register of those who meet its requirements
In response to the Covid-19 pandemic, the HCPC established a temporary register of former registrants (those who had de-registered within the previous three years) and final year students. The HCPC received seven fitness to practise referrals about individuals on the temporary register and revoked the temporary registration in all of those cases. It had not identified any instances of individuals being given temporary registration inappropriately.
Fitness to Practise
The HCPC has not met four of the five Standards for fitness to practise. Following our audit last year, we had concerns about:
- the quality and timeliness of the HCPC’s investigations into issues raised about registrants
- decision-making at all stages of the HCPC’s fitness to practise process
- the HCPC’s compliance with its own policies the quality and frequency of risk assessments completed by staff
- record-keeping
- the customer service and support provided to those involved in fitness to practise proceedings.
During the review period, the HCPC developed a fitness to practise improvement programme to address those concerns. The programme details the structural and process changes required to improve its performance. The implementation of some aspects of the programme were delayed by the Covid-19 pandemic.
In October 2020, the HCPC introduced Senior Decision Makers, who are responsible for assessing all relevant cases against the Threshold policy. The process may alleviate the significant concerns we previously identified about the HCPC’s decision-making at the early stages of its processes and may lead to more consistent and fair decisions being made.
The HCPC also developed:
- case plans for cases where progression has been limited due to the Covid-19 pandemic, which has been rolled out to all investigations
- a new risk assessment tool
- a registrant health and wellbeing strategy and action plan 2021-24 which should improve support issued to all parties of a complaint to participate effectively in the fitness to practise process.
If properly implemented, the improvement activities should improve the HCPC’s performance in the areas identified. We will continue to closely scrutinise the HCPC’s performance in this area.