The draft Bill outlines Government proposals for a single law for adult care and support that replaces existing legislation. The bill includes a number of health measures, including the law needed to establish Health Education England and the Health Research Authority. The College’s response to this consultation focused on priority areas such as the new education and training system, the role of professional bodies, the establishment of Health Education England, and the statutory footing of Local Education and Training Boards (LETBs).
In response to a call for evidence regarding the safety and regulation of cosmetic surgery and procedures by the Department of Health, the Royal College of Surgeons highlighted the importance of appropriate training of those who perform these procedures. The College recommended that only licensed doctors, registered dentists and registered nurses should provide any cosmetic treatments (including laser treatments and injectable cosmetic treatments). This would ensure appropriate levels of expertise and professional standards are in place to support a high level of ethical standards and safety of cosmetic procedures.
Responding to proposals to merge the Human Tissue Authority (HTA) into the Care Quality Commission, the College recommended that the HTA retain its existing functions while delivering efficiencies.
The NHS Commissioning Board draft mandate aims to establish a framework to manage the relationship between the Department of Health and the NHS Commissioning Board (NHSCB), and to outline care objectives for the improvement of health and healthcare. Contributing to a consultation to set out the detail of this mandate the College supports the broad, over-arching principles and objectives but made a number of recommendations. The College would like to see the broad principles of the mandate stating the commitment to both education and training, and research, which are vital to improving the quality of care for patients.
Study into the Management of Hospital Consultants, July 2012
The College has fed into the National Audit Office’s study on the management of hospital consultants.
Following the PIP breast implant and metal-on-metal hip replacement controversies, the College responded to an inquiry by the Science and Technology Select Committee into the regulation of implantable medical devices. Highlighting the importance of medical implantation for improving patient’s lives we focus on ways to improve patient safety by increasing transparency, clearly defining the role of clinicians to improve post-market surveillance, and increasing harmonisation of regulatory standards across Europe.
The College responded to the recently proposed draft directive that guides the mobility of doctors and other professionals within the Member States of the EU. Some of the previous College concerns have been addressed in the proposals, however in this response we reiterate our concerns about issues such as language checking and CPD. We also raise a concern about the proposed minimum training requirements for dentists.
The College has responded to the CfWI's discussion paper on the shape of the medical workforce. The CfWI put forward a number of scenarios on which to base future workforce plans. The College outlines its concerns regarding the lack of detail in the CfWI's approach and urges greater engagement with the College and specialty associations so as to ensure the availability of appropriately trained surgeons to treat patients in the future.
The College responded to the General Medical Council consultation on the revised edition of the 2006 core GMC guidance Good Medical Practice. The College supports the new emphasis on effective handovers and continuity of care. We are also supportive of the reorganisation of the guidance into four headings, in line with the framework for appraisal and assessment, which we hope will help doctors prepare for revalidation and reduce confusion over what is the definitive document against which to judge fitness to practise. However, we think that greater degree of content from GMC supplementary guidance such as guidance on consent, confidentiality and conflicts of interest should be included in the core document to minimise the degree to which doctors have to seek out additional guidance.
The College responded to the NICE consultation on the Commissioning Outcomes Framework (COF). The intention is for the COF to act as an accountability framework to enable the NHS Commissioning Board to identify the contribution of Clinical Commissioning Groups in achieving the priorities set out in the NHS Outcomes Framework. The College is broadly supportive of the COF but considers it essential that NICE consults closely with the surgical specialty associations and related groups on the development of the COF indicators.
The College responded to the Welsh Government document Together for Health: A 5 Year Vision for the NHS in Wales. The College supports the aspirations of the strategy, and calls for the role and value of surgery to be properly accounted for as the strategy is taken forward.
The Department of Health consulted on ways to embed candour (transparency and openness with patients) through contractual mechanisms. The College recognises the need for candour, but recommends that the Department of Health facillitate this through education and training resources that are already available, but under-utilised. These have been shown to help healthcare providers foster an ingrained culture of openness and information-sharing that results in learning and improvement for staff, and high quality services for patients.
The College responded to proposals for independent prescribing by podiatrists from the Department of Health. In the response the College recognises the demands and expectations of patients to access medication at the time of their treatment but urge for caution in areas of podiatry involving invasive surgical procedures. Therefore in order to realise some of the patient benefits outlined in the consultation document whilst ensuring patient safety, we support independent prescribing for podiatrists for specified conditions from a specified formulary.
The European Commission requested feedback on proposals to modernise the Directive on Mutual Recognition of Professional Qualifications. The College recognises the timeliness of this review, but broadly cautions proposals to relax the Directive's requirements. Instead, we call for focus on ways to implement current requirements in a manner that ensures patient safety whilst increasing the speed and efficiency of the qualification recognition process.
The Government published the Health and Social Care Bill on the 19 January 2011. The College has produced this briefing document ahead of the Second Reading of the Bill.
The Government called for responses to their white paper on proposals for reforming the NHS. The College response commends the approach to put patients at the heart of the NHS along with a focus on clinical outcomes and leadership and a move away from targets that have no clinical relevance. We highlight the need for partnerships between primary care and hospital clinicians if specialist services are going to be commissioned to meet needs of patients. We also welcome the intention to lead education commissioning both locally and nationally through Medical Education England (MEE) for doctors, dentists, healthcare scientists and pharmacists.
Specific NHS White Paper consultation responses:
- NHS Future Forum response - Education and Training (November 2011)
- NHS Future Forum response - Information (November 2011)
- NHS Future Forum response - Integrated Services (November 2011)
- NHS Future Forum response (May 2011)
- Developing the Healthcare Workforce (March 2011)
- Greater choice and control (January 2011)
- Information Revolution (January 2011)
- Regulating Healthcare Providers (September 2010)
- Democratic Legitimacy in Health (September 2010)
- Commissioning for Patients (September 2010)
- Outcomes Framework (September 2010)
The Department of Health is seeking to update the national response strategy for pandemic influenza. The College calls for clearer guidance around decisions to stop elective services, and greater ease in accessing available guidance during a pandemic.
The College responded to a call for views from the Comission on Assisted Dying. The College do not want the current laws to be changed, and do not envisage any circumstances under which it would be acceptable for a medical professional to assist the death of a patient.
The European Commission are reviewing the Directive on the recognition of Professional Qualifications. The College response calls for an appropriate balance to be struck between worker mobility and patient safety. In particular we call for assurances that the current safeguards around language and communications are not compromised, and that harmonisation of standards will not result in a reduction of quality in those member states where standards exceed the European average.
The European Commission called on the EU Social Partners to provide input on the revision of the Working Time Directive. The College highlighted the need for flexibility in the Directive. Specifically, the need to address the issue of compensatory rest and on-call time. The College also called for the option to exclude those who work in 24 hour hospital services.
The College responded to the House of Commons Health Select Committee follow-up inquiry into commissioning. In February 2011 the Health Select Committee called for evidence to support specific recommendations of their January 2011 commissioning report. The College welcomed the focus on clinical involvement in commissioning but raised several unresolved concerns in the proposed arrangements for system reform. These concerns included: the need for a formal requirement to involve specialists in commissioning decisions both locally and nationally; the need for commissioning and oversight on a regional or supra-regional basis; the future provision of training of healthcare professionals; and the potential for inconsistent application of national standards.
The Department of Health have proposed that more explicit and comprehensive advice about whistleblowing should be included in the NHS constitution and accompanying guidance. The College is supportive of initiatives that highlight the importance of raising concerns in the health service. This guidance should however be backed up by practical support and initiatives for healthcare providers and clinicians.