Regulation of Health Care Staff in England and Wales

DH Consultation document 2/3/2004. Ref 2121

Official response from the Association of Anatomical Pathology Technologists (UK) (AAPT (UK))

Q1. How far should assistants and support staff be accountable for their own practice?

Q2. Should assistants and support staff set their own standards OR should those with overall responsibility for the work of these staff share in, or take, the lead in setting these standards?

Anatomical Pathology Technologists (APTs) have direct impact on patient clinical care through their work with the deceased from hospitals and the community – irrespective of whether and autopsy is involved or not. They interact and advise relatives of the deceased.

APTs are a profession represented by the AAPT (UK) that is in the second tier, commencing 2007, of aspirant groups for HPC regulation. The AAPT (UK) is preparing codes of practice for its members and these APTs should be fully accountable for their own practice.

Assistants and support staff to APTs would include Assistant Technical Officers (ATO) and Senior ATOs. They are responsible and accountable to APTs and have their standards set by APTs.

Q3. Should regulatory arrangements be extended to healthcare assistants, therapy assistants, assistant practitioners, and other’s performing similar roles in routine care? If not, which staff should be included and on what criteria?

All staff involved directly with patients should be regulated.

Q4. Is statutory regulation appropriate or should other approaches be taken?

APTs are an aspirant group alongside others who also wish to be regulated by HPC in 2007. In numbers, they comprise about 1000 staff in the UK. Therefore it is likely that they will share a voluntary registration council with other aspirant groups, working towards statutory self- or shared regulation. In the first instance, shared regulation in acceptable and the smoothest way forward.

Q5. Should the Health Professions Council (HPC) regulate those groups of assistants and support staff identified for statutory regulation? Are other options preferable?

Ultimately, the HPC should regulate this and all other groups. This will ensure high standards of performance in daily and the confidence of the public; and avoid a two-tier health care scientist structure. In the first instance, there will be a Voluntary Registration Council for Healthcare Scientists (the aspirant groups for 2007 regulation), on which the AAPT (UK) will be a member group.

Q6. If the HPC is the most appropriate body, should regulation be by way of a statutory Health Occupations Committee or would other options be preferable?

The statutory Health Occupations Committee is the appropriate body for regulation.

Q7. Would regulation of assistants and support staff by the bodies responsible for regulating those whom they support lead to other problems such as ‘second class’ workers?

Assistants and support staff include ATOs (see above). The AAPT (UK) will set their training, standards and be responsible for their work, and AAPT (UK) does not believe that this will create a ‘second class’ of worker. It is and will be possible for ATOs to undergo further training and qualify as APTs, under Agenda for Change and KSF.

Q8. Are there other options for the structure of statutory self-regulation we should consider?

No

Q9. How can multi-disciplinary issues best be addressed? Should the regulators set common standards and/or recognise each other’s so that workers can move between different health and social care settings without the need for multiple registration? OR Could all assistants and support staff be regulated as a single group within a single framework including come shared standards and some discipline-specific standards?

In many places, APTs also act as bereavement officers, with a role in counselling relatives of the deceased. This interactive relationship of APTs with relatives will become increasingly important in the future with improved communications over affairs relating to death. Qualified bereavement counselling is a skill that APTs may acquire through additional training. (It is unlikely that many bereavement officers would re-train as APTs). Regulators should set common standards and recognise each other’s so that there will not be a need for multiple registration.

Prof SB Lucas, President AAPT (UK)
Mr James Lowell, Vice Chairman, AAPT (UK)
4th June 2004