Raising a concern about an HCPC approved education or training programme
Contents About this document... 3 Introduction... 4 About us... 4 Who do we regulate?... 4 Our main functions... 4 The education complaints process... 6 How to make a complaint... 6 Other complaints procedures... 7 Education complaints and our fitness to practise process... 7 What we will do when we receive a complaint... 8 1 Assessment... 9 2 Investigation... 9 3 Education and Training Committee... 10 Appendix: Resources... 10 2
About this document This document provides information for anyone thinking about raising a concern about an education or training programme that we (the Health and Care Professions Council) have approved. To be approved, the programme must meet the standards we set. If you raise a concern about an education or training programme, we will take steps to make sure that the programme still meets our standards. This document explains: how you can raise a concern about an approved education or training programme; how we will investigate your concern; and the possible outcomes of a concern. If you need any more information, please contact a member of our Education Department. Phone: 020 7840 9812 Fax: 020 7820 9684 Email: concerns@hcpc-uk.org If you want to raise a concern about an education or training programme, you need to fill in our concerns form and send it to: Director of Education The Health and Care Professions Council Park House 184 Kennington Park Road London SE11 4BU 3
Introduction About us We are the Health and Care Professions Council (HCPC). We are responsible for protecting the health and wellbeing of people who use the services of the health and care professionals registered with us. We do this by keeping a register of health and care professionals who meet our standards for their training, professional skills, behaviour and health. Health and care professionals on our Register are called registrants. Who do we regulate? We currently regulate the following professions. Arts therapists Biomedical scientists Chiropodists / podiatrists Clinical scientists Dietitians Hearing aid dispensers Occupational therapists Operating department practitioners Orthoptists Paramedics Physiotherapists Practitioner psychologists Prosthetists / Orthotists Radiographers Social workers in England Speech and language therapists We may regulate other professions in the future. For an up-to-date list of the professions we regulate, please see our website at www.hcpc-uk.org Each profession has at least one professional title that is protected by law. It is a criminal offence to claim to be registered with us if you are not, or to use a protected title that you are not entitled to use. We will prosecute people who commit these crimes. Our main functions To protect the public we: set standards for the education and training, professional skills, conduct, performance, ethics and health of our registrants; 4
keep a register of health and care professionals who meet these standards; approve education and training programmes that health and care professionals must complete before they can register with us; and take action when health and care professionals on our Register do not meet our standards. The Health and Social Work Professions Order 2001 says that we must set our standards to protect the public, and that we must set standards which are necessary for safe and effective practice. This is why we have set our standards at a threshold or minimum level. Each of the professions we regulate has education and training programmes and education and training providers associated with them. Our standards of education and training (SETs) are the standards that all education and training programmes must meet before we can approve them. As well as approving education and training for people who want to join the Register, we also approve a small number of qualifications for those already on the Register. We call these post-registration programmes and we currently approve: supplementary and independent prescribing programmes (for chiropodists / podiatrists, radiographers and physiotherapists); programmes in local anaesthetics and prescription-only medicine for chiropodists / podiatrists; and approved mental health practitioners. We make a note on the Register against the names of registrants who successfully complete supplementary prescribing, independent prescribing, local anaesthetics and prescription-only medicine programmes. You can see from the list on our website (www.hcpc-uk.org) that approved education and training programmes are delivered by a range of education and training providers. The education and training providers range from large universities to smaller, independent providers. No matter what type of provider they are, or what programme they offer, the programme must meet all our standards and be approved by us, so that those who complete the programme will be eligible to apply to register with us. Our Education Department is responsible for approving and monitoring education and training programmes throughout the UK against our SETs to make sure that, when qualified, all students meet our standards of proficiency. We do this by visiting programmes to assess whether they meet all of the standards. Once we have approved a programme we monitor that programme to make sure it continues to meet our standards. 5
The education concerns process We aim to run a clear and open concerns process. You should be aware that, if you raise a concern and we investigate a particular programme, the outcome will only affect whether we continue to approve that particular education or training programme. It will not lead to any financial compensation for you, or a change in your grade or award classification. We will not take any action in response to concerns which are: unwarranted (not well-founded); about the academic judgement of a training or education provider; about an individual s fitness for an academic award; or frivolous (not serious). We expect to deal with most concerns within six months of receiving the concern. However, this depends on what the concern is about and how complicated the concern is. We would normally expect you to have been through all other procedures appropriate to your concern, especially the education or training provider s own concerns procedure, before we consider the concern. How to raise a concern Your concern must be made in writing and include the details of the education or training provider and the details of your concern. If you find it difficult to put your concern in writing, you can ask someone to write it out for you and sign it on your behalf, but you will need to include an explanation of why this was necessary. We have produced a concern form that you can download from our website or we can send you a copy if you ask us to. We encourage you to use our concern form because we need your answers to the particular questions we ask on it. This helps us to understand your concern and confirm which concerns processes you may already have been through. If you decide not to use our concern form, you must make sure that you include the following information in your concern. The name of the education or training provider involved. The name of the education or training programme you are raising a concern about. Brief details of any other concerns processes your concern has already gone through, or is currently going through, including any findings. A summary of what you are raising a concern about. 6
Permission to send your concern to the education provider, along with any evidence you have provided. Permission to take your concern through all stages of the process. If you do not include the above information in your concern, we will ask you for the missing information. Please note that we will send details of your concern to the education or training provider so that they can reply to us about the points you have raised. If you are unhappy about us passing on the details of your concern, please let us know when you send your concern to us. Other concerns procedures Anybody can raise a concern with us about an education or training programme. As well as our concerns process, education and training providers normally have their own concerns procedure that you can use. Our process for concerns about approved education and training programmes is independent of any other concerns procedure. Most of the concerns procedures about education or training programmes are for students to use. There is a list of some of the available concerns procedures in the appendix and you may find that they are more appropriate for your concern. In most cases, we would expect you to have been through all other appropriate concerns procedures, especially the education or training provider s own concern procedure, before we investigate your concern. We would normally want to see evidence of all the other procedures that your concern has been through and the outcome of these procedures. However, we also understand that there may be some cases where it has not been possible to go through any other concerns procedures. If this is the case, you will need to explain why. There is no time limit on our procedure for considering a concern about an education or training programme. However, we can only consider a concern about a programme that is currently approved by us, and that was approved by us at the time you raised your concern. Education concerns and our fitness to practise process As a regulator we set the standards that all our registrants must keep to. The behaviour and level of skills and knowledge we expect from a registrant are set out in the Standards of conduct, performance and ethics and the Standards of proficiency sections on our website. (For more information, please see www.hcpc-uk.org/aboutregistration/standards) 7
When a registrant keeps to these standards, we describe them as fit to practise. This means you can be confident that they have the health and character, as well as the necessary skills and knowledge, to do their job safely and effectively. Our Fitness to Practise Department is responsible for handling concerns about whether a registrant is fit to practise. These concerns are known as allegations. The education concerns process and the fitness to practise concerns process are separate. Our education concerns process considers information about one of our approved programmes and whether it still meets our standards. If your concern is about an individual registrant s fitness to practise, you need to contact our Fitness to Practise Department. For more information on making a concern about a registrant, please see the relevant section of our website (www.hcpcuk.org/complaints). If, during a fitness to practise investigation, we find that there are systemic failings (widespread problems) with an education or training programme, when they have finished their investigation, our Fitness to Practise Department will pass information about this to our Education Department. At this time, we may ask you to raise a separate concern about an education or training provider in writing, if you have not already done so. What we will do when we receive a concern Concerns about an education or training programme are normally made to our Education Department. They will check: that you have provided all the necessary information for us to investigate your concern; what stage any concerns you have made to other organisations are up to; and that you have included the necessary evidence to support your concern. We will acknowledge your concern within 10 working days of receiving it. If you have not sent us all the information we need to investigate your concern, we will write to you and explain what information is missing. Once we receive your concern in full, our Fitness to Practise Department and Education Department will jointly consider it to make sure it is not about an individual s fitness to practise. If it is not about an individual's fitness to practise, the Education Department can begin to investigate the concern. We must make sure that the right department deals with your concern. If we feel that your concern is about an individual registrant rather than an education or training programme, our Fitness to Practise Department will take over and complete their investigations before our Education Department considers the concern. Once any fitness to practise case is complete, we will contact you to 8
find out if you still want to raise a concern about the education or training programme. 1 Assessment Our Education Department assesses your concern to decide whether your concern relates to the programme, the programme provider or the organisation awarding the qualification. To decide whether to investigate your concern, we will consider whether the information you have provided puts any of the following in doubt. Whether the programme still meets our standards of education and training. Whether the people who complete the programme will still be able to meet our standards of proficiency. Whether students on the programme will still be able to meet our standards of conduct, performance and ethics. If your concern does not meet any of these conditions, we will write to you and explain why we cannot consider your concern any further. 2 Investigation If we decide to investigate your concern, a member of the Education Department will be responsible for leading the investigation into your concern about an approved programme. This person will be your contact while we investigate your concern. They will contact you to give you their name and contact details, update you during the investigation and ask you for more information if they need it. Our investigation will focus on the specific details of your concern rather than considering the programme as a whole. Except in unusual circumstances, we will send the details of your concern to the education or training provider so that they know the details of your concern and can reply to them. They have 28 days to reply to us. We will also ask them for details of any changes they have made to their education or training programme since your concern went through their own concerns process. Once we have received a reply to your concern from the education or training provider, we may ask them for more information, or we may ask you for more information. If your concern or the reply from the education or training provider deals with knowledge, skills or expertise that is specific to a profession, we may ask one or more of our partners to review the information. Our partners are members of the professions we regulate and we refer to them when we need information about specialist knowledge or skills. We will make sure we do not use partners who are already involved directly, or indirectly, in your concern. 9
When the Education Department has completed its investigation, it will prepare a report giving details of the investigation along with its recommendations. We will send copies of this report to you and to the education or training provider. Both you and the education or training provider will then have 28 days from receiving the report to send us your comments. 3 Education and Training Committee The Education and Training Committee (ETC) is made up of health and care professionals and members of the public. As part of its role, it makes decisions about the concerns we receive. The ETC will consider our investigation report and recommend one of the following three options. a Take no action This means that we will continue to approve the programme. b Pass on the information from the concern to the appropriate approval or monitoring process This means that as a result of the investigation, we found that the education or training provider had made changes to the programme. However, these changes do not mean that the programme has failed to meet the standards we use to approve programmes (the standards of education and training) or the standards that registrants must meet to join our Register (the standards of proficiency and the standards of conduct, performance and ethics) in a way that means we need to take immediate action. Depending on the changes the education or training provider has made to the programme, we will use one of our Education Department processes to check that the programme continues to meet all our standards. These processes are the ones we use regularly to approve education and training programmes in the first place, and then to continue monitoring them. c Carry out a further investigation If the ETC has particular and serious concerns that a programme is failing to meet the standards of education and training or standards of proficiency, or that there is a risk to the public, the ETC may decide to carry out a further investigation by making a directed visit. During a directed visit, our representatives will visit the education or training provider and look at a programme in detail, based on directions given by the ETC. After a directed visit, the ETC will make a final decision on the programme. 10
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Appendix: Resources We have designed our concerns process so that we can consider whether to continue approving a particular programme. The following is not a full list and you may find other concerns procedures that are more appropriate for your concern. However, we feel it is useful to give you a list of some other concerns procedures, as well as those that belong to us. Although we are providing these details, this does not mean that we are approving any procedures that we do not offer. Resource Organisation Responsibilities Available from Internal concerns process Education or training provider Various How to complain about a health or social care service An introduction to our education processes Annual monitoring supplementary information for education providers Approval process supplementary Equality and Human Rights Commission Care Quality Commission The Health and Care Professions Council A process that an education or training provider may use to consider concerns internally. An independent organisation set up to help remove discrimination and protect human rights. An independent organisation set up to regulate all health and adult social care services in England. We regulate 16 health professions. The education or training provider www.equalityhumanrights.com www.cqc.org.uk www.hcpc-uk.org 12
information for education providers How to raise a concern How to make a complaint to the Health and Care Professions Council (HCPC) Major change supplementary information for education providers Standards of conduct, performance and ethics Standards of education and training Standards of proficiency Making a complaint to the OIA Code of practice for the assurance of academic quality and standards in higher education The Office of the Independent Adjudicator for Higher Education Quality Assurance Agency It runs an independent concerns scheme for students raising a complaint about higher education institutions in England and Wales. An independent agency responsible for dealing with concerns and appeals on academic matters made by students. www.oiahe.org.uk www.qaa.ac.uk 13
Bringing a complaint to the Health Service Ombudsman Making a complaint Public Body Complaint Health Complaints Parliamentary and Health Service Ombudsman Scottish Public Services Ombudsman Public Services Ombudsman for Wales Northern Ireland Ombudsman It allows people to raise concerns about any organisation that provides public services in the UK, and the NHS in England. It allows people to raise a concern about any organisation that provides public services in Scotland. It allows people to raise a concern about any organisation that provides public services in Wales. It allows people to raise a concern about any organisation that provides public services in Northern Ireland. www.ombudsman.org.uk www.spso.org.uk www.ombudsman-wales.org.uk www.ni-ombudsman.org.uk 14