Association of Anatomical Pathology Technology


Professional Standards Authority consultation on the future shape of the Accredited Registers programme

The AAPT has today sent it's official response to the PSA consultation on accredited registers


The PSA strategic review of the Accredited Registers programme was launched in June this year and is the first comprehensive review of the programme since its creation in 2012. The Accredited Registers programme provides a system of oversight and assurance for healthcare roles which are not regulated by law and in the last eight years has accredited a range of registers covering a wide variety of occupations.

In this consultation, the PSA set out their vision for the future and our proposals for changes to the programme during 2021.

The AAPT today responded as follows to the questions set out in the consultation:

Question 1: Do you agree that a system of voluntary registration of health and social care practitioners can be effective in protecting the public? 


As you recognise in your consultation document, effective voluntary registration is contingent on both recognition and use by the broader systems in which it operates (i.e. employers), and on high levels of coverage. As it stands, neither of these pre-requisites for successful regulation have been met or are likely to be met.

To put the situation in context, consider the profession we represent when assessing these two pre-requisites:

Recognition and use:

Currently, we are not aware of a single employer who lists registration with the Academy for Healthcare Science (AHCS) as an essential requirement when recruiting. Given the level of coverage (see below), to do so would narrow the field of available to such an extent as to make appointment of this ‘hard-to-recruit’ profession virtually impossible. However laudable the aims of the voluntary registers, we believe that employers will only consistently require registration when they are required by statute to do so, especially in times of increasing budget constraint.

In addition to the lack of recognition, voluntary registration has, in some places, created a two-tier system, in which professions not regulated by statute are seen as inferior or ‘not as scientific’ as those that are. This is often seen in the mortuary sector, where an increasing number of mortuary management positions are being taken by HCPC-registered staff, sometimes regardless of relative sector experience. A stated aim of the AHCS is for the Healthcare Science workforce to speak with ‘one voice’, but this is increasingly difficult when the manner of regulation is so different between different HCS occupations.

Levels of coverage:

There are around 700 practicing Anatomical Pathology Technologists in the UK at any one time. Currently, 48 (or 6.9%) are registered with AHCS. This number is almost certainly inflated by the fact that we (AAPT) mandate registration with ACHS as a requirement for serving on our Council or being an External Assessor. By any metric, a coverage of 6.9% of a profession cannot credibly be claimed to provide public protection.

We would consider the Anatomical Pathology Technology profession to be a high-risk one, by virtue of the fact that:

  • Anatomical Pathology Technologist’ is not a protected job title, meaning there is no set definition of what constitutes an APT
  • Anatomical Pathology Technologists do not have a protected scope of practice, meaning that staff can, perfectly legally, be employed in mortuaries on a low administrative or assistant grade, and be asked to complete tasks that are not appropriate for them to do, such as the evisceration and reconstruction of the deceased, involvement in forensic examinations and contact with bereaved people. The only standards set-out in this regard are in our regulator’s standards (the Human Tissue Authority [HTA]), which state that “all staff who are involved in mortuary duties are appropriately trained/qualified”, but without defining what constitutes ‘appropriate’ training or qualification.
  • The impact of improper actions by an APT can be far-reaching and profound, such as negatively affecting criminal cases, affecting the quality of diagnostic tests, causing extreme distress to the public and other issues, which are often high-profile and involve legal action.
  • The model of regulation of mortuaries in England and Wales involves the licensing and regulation of establishments, not individuals, and therefore, patient safety is vulnerable to a lack of control of unsuitable staff – particularly involving locum or temporary staff, as the pandemic has highlighted. Such staff can simply move on to other employment with no impediment to their practice.

As you state in your consultation document, “the voluntary nature of the programme currently cannot prevent an individual from practising independently in an occupation which is not regulated by law”. We believe this to be the crux of the weakness with voluntary regulation, and one that is likely to remain intractable without statutory regulation.

An additional factor that may be deterring staff from applying to the voluntary registers is that it can create a split among departments, where registered staff are subject to more scrutiny and potential sanctions when things go wrong – sometimes even in respect of the same incident. We believe that all practising APTs should be required to be held to the same standards and that effective and fair scrutiny should be applied consistently across the whole profession.

Question 2: How do you think the Authority should determine which occupations should be included within the scope of the programme? Is there anything further you would like us to consider in relation to assessing applications for new registers?

We consider the options outlined in your consultation document to be effective ways of establishing suitability.

Question 3: Do you think that moving from an annual to a longer cycle of renewal of accreditation, proportionate to risk, will enable the Authority to take a targeted, proportionate and agile approach to assessment? Do you think our proposals for new registers in terms of minimum requirements are reasonable?

As long as the relative risk of each profession is effectively assessed, and effective audit activity is undertaken in between renewals to identify issues, we consider the proposals to be reasonable.

Question 4: Do you think accreditation has been interpreted as implying endorsement of the occupations it registers? Is this problematic? If so, how might this be mitigated for the future? 

Yes, we believe there is a risk of implicit approval. We recognise that a scientific, positivist perspective is not appropriate for assessing all occupations, but great care must be taken to avoid endorsing treatments or practitioners who are unable to demonstrate a credible basis for their activity.

Question 5: Do you think the Authority should take account of evidence of effectiveness of occupations in its accreditation decisions, and if so, what is the best way to achieve this? 

In recognition of the fact that not every treatment or occupation will have a good quality evidence-base (e.g. systematic review or randomised controlled trial) we suggest that alternatives are considered as an adjunct to evidence (i.e. a combination of the three options you lay out: knowledge base, evidence base and external proxies). 

Question 6: Do you think that changing the funding model to a ‘per-registrant’ fee is reasonable? Are there any other models you would like us to consider?

We feel that any increase in the fee charged to registrants, even a relatively small one such as you suggest (£6 per registrant), will result in a decease in the number of registrants. Uptake of, and confidence in, voluntary regulation is already very low, and we consider it would not take much to tip the cost-benefit analysis in the wrong direction. A decrease in the proportion of APTs on the register would further undermine the register’s credibility, with those remaining on the register increasingly questioning what the benefit of voluntary registration is to them.

Question 7: Do you think that our proposals for the future vision would achieve greater use and recognition of the programme by patients, the public, and employers? Are there any further changes you would like us to consider? 

Yes, however, while the concept remains voluntary, there will be gaps in protection and the public will be at risk – we would argue that it’s not practitioners who have voluntarily been bound to uphold certain standards that we need to worry about, it’s those who reject regulation.

The only way this could conceivably succeed, is if the programme gained the backing of government in ‘requiring’ employers to set voluntary registration (either existing or a commitment to become registered within a set time period) as an essential criterion during recruitment – thereby making it an individual choice whether to register, but a condition of employment (so-called ‘mandatory voluntary registration’). It’s difficult to see how that could be achieved without a statutory compulsion. This is demonstrated by the situation in Scotland, where voluntary regulation has been identified as a priority and HR departments have been strongly encouraged to mandate it, but the expected take-up has not materialised.  

Question 8: Do you agree that to protect the public, the Accredited Registers should be allowed to access information about relevant spent convictions?

Yes, but only for occupations deemed to pose a higher risk (i.e. intermediate risk in your proposal).

Question 9: Are there any aspects of these proposals that you feel could result in differential treatment of, or impact on, groups or individuals with characteristics protected by the Equality Act 2010?

Yes. Insufficient protection for the public (as outlined in our response to question 1) could very well result in individuals from all such populations being disadvantaged or otherwise impacted by poor practice.


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