Policy responses and statements
Background: PMETB invited comments on consultation paper about the Rules which it proposes to amend in regard to the setting of fees. The paper provides the rationale for the proposed changes to the fees charged by PMETB from 1st April 2006 to 31st March 2007. It complements the proposed fees rules. The year 2006/7 will be PMETB's first full working year, and the real cost of its work evident for the first time. PMETB's current fee level is only possible because of the considerable financial support provided by government. The Departments of Health have said that, whilst they will continue to fund the PMETB's work, as an independent authority they expect the organisation to be financially self-supporting. Their grants will therefore be on a reducing scale. Fees are the only way in which PMETB can meet that difference. This consultation paper invited views on draft rules which set the fees to be charged by PMETB for the exercise of its functions. Views are invited from stakeholders on the proposed approach.
Jan Quirke 11th January 2006 Dear Ms Quirke PMETB FEES CONSULTATION This letter is written on behalf of the Federation of Royal Colleges of Physicians of the UK [Edinburgh, Glasgow and London], in response to the PMETB fees consultation document. Our general comment would be that these proposals seem less to do with the delivery of benefits to those in training than for the acute need of the PMETB to balance its books. If it were not so, then a much longer period of bedding down would be possible before such a large increase was proposed. It is of concern that the PMETB appears to be costing in the order of two to three times the amount required by its forebear authorities, and that the burden of supporting this falls on trainees in advance of the proposed benefits being realised. 1. Principles underpinning the proposals [paragraph 8] Principles one and two are un-contentious being derived from the requirements of the order. Principle three the beneficiary pays is less so. Many of those in training will not see themselves as the only beneficiaries and would argue that the service is a major beneficiary of improved PME in the shape of better and more appropriately trained practitioners and because of the much publicised reduction in the burden of QA visits. Principle 4 reinforces this view – it will not be only those gaining entry to the registers benefiting from higher standards. Principle 5 seeks to, but doesn’t quite succeed in, finding a pragmatic and fair way of meeting the costs of appeals. Principle 6 is prudent and reasonable. 2. Are the proposals consistent with the principles? Principles 2 and 4 emphasise the role of PMETB in acting as a body not only to set and maintain standards and ensure quality but also to develop and promote PME. Principle 3 says that the beneficiary pays. A dispassionate observer might conclude that if the PMETB is to concentrate on these high level activities, whilst expecting Royal Colleges and the Postgraduate Deans to be responsible for the detailed delivery, it would be difficult to believe that a tripling of the CCT fee provides value for money. Paragraphs 3.2 and 3.3 set out a number of practical examples of where the PMETB claims to have delivered benefits, in the production of standards, principles and criteria etc. There are not many who would consider that the efficacy of these benefits has been demonstrated such that a tripling of the CCT fee can be justified so soon. 3. Comments on the proposals [paragraphs 9 & 10] As intimated in our comments at (2) above, we believe that the level of CCT fee at £750 and the increase of the A11/14 fee from 1st April 2006 are excessive given the lack of firm evidence that the PMETB has yet to deliver any substantial benefits to those expected to pay, particularly those just coming to the end of training. The appeal fee is probably as high as it could reasonably be set. However the fact that A11/14 applicants will already have paid significant sums for evaluation might mean that the PMETB could be subject to accusations of “pricing A11/14 appellants out”, and thus to accusations of discrimination. For example, if someone appeals against non-award of CCT s/he will benefit from not [yet] having had to pay any CCT fee. This might be considered unfair since the A11/14 applicant would be significantly out of pocket already having paid a £700 [soon to be £1250] fee for evaluation. Perhaps a more graded level of fee should be considered. The level and complexity of appeals may be ameliorated by not seeking legal opinion/representation on cases where there are no matters of law involved. 4. Comments on the proposed future approach to revising the fee structure [paragraph 11] The PMETB’s approach to reviewing its fees in the future is to be welcomed, particularly the commitment to review fee levels in the light of potential alternative income streams. 5. As we stated at the beginning of this letter, we are concerned that the PMETB has proved to be a much more expensive body than originally envisaged. For example we are amazed at the enormous and unwieldy bureaucracy that has been developed around the administration of A11/14 applications; which has been in operation for six months already and has yet to deliver a single application to the JCHMT for evaluation. The proposed budget for PMETB for the year 2006/2007 indicates that the level of DH funding represents 38% of the Board’s required income. This is a significant percentage. The money currently being provided by the DH to the Colleges as grant in aid is supposed to be passed to Colleges, through the PMETB, from April 2007. We have concerns that this money will form the bulk of the DHs support for PMETB for that year, and will not therefore filter down to the Colleges. The removal or reduction of this grant money will have a serious impact upon Colleges whilst at the same time they are being asked to assist with the delivery of the PMETB’s standards. Given this situation, it seems perverse for the PMETB to intimate on page 29 of the consultation paper that College fees should not need to be increased. The Board argues that less heavy QA costs are to be incurred by Colleges whilst at the same time expecting them to assist Postgraduate Deans with the quality control of PME on the ground. That being said, QA forms only a part of the work Colleges have done and will continue to do. They are still being asked to prepare specialty curricula, contribute to assessment policy and delivery, undertake local QC with Deans, monitor individuals’ training and recommend doctors for CCT. Article 11/14 work is of course subject to a separate agreement at present but the Colleges are crucial to the evaluation process. In fact only about 28% of the DH grant in aid is at present devoted to QA visits, at least as far as the three Physician Colleges are concerned. The PMETB is committed to working with the Colleges but to penalise them financially simply because the Board itself has financial problems is not a constructive approach. Colleges will simply not be prepared to deliver work that PMETB demands of them, funded from their own resources. Finally, to imply that the College examinations are obsolete in the face of competence assessment is presumptive, particularly given the emerging interest in knowledge based assessment, which may have an examination component under MMC. Yours sincerely Dr Chris Clough FRCP cc: Presidents and Chief Executive Officers of the three RCsP
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