Policy responses and statements

Name of organisation:: Department of Health
Name of policy document:: Competence and curriculum framework for the emergency care practitioner - Consultation document
Deadline for response:: 29 September 2006

Background: The purpose of this document is to share progress that has been made on the development of a new healthcare role, and to seek comments on the proposed Competence and Curriculum Framework. Following the consultation process, comments received will be incorporated into a final document which will inform the development of the role and educational programmes as part of whole workforce planning by health economies.

What is an Emergency Care Practitioner (ECP)?

An ECP is a healthcare professional who works to a medical model, with the attitude, skills and knowledge base to deliver holistic care and treatment within the pre-hospital, primary and acute care settings with a broadly defined level of autonomy.

The Department of Health would welcome comments on:

- the Curriculum Framework as the basis for the development of educational programmes
- entry routes
- core competences
- core clinical skills
- arrangements for teaching and supervision
- methods of assessment, pre and post registration and national support structures
- title for the new role
- proposed regulation of the role

COMMENTS ON
DEPARTMENT OF HEALTH
COMPETENCE AND CURRICULUM FRAMEWORK FOR THE EMERGENCY CARE PRACTITIONER

The Royal College of Physicians of Edinburgh is pleased to respond to the Department of Health on its consultation on the Competence and curriculum framework for the emergency care practitioner.

INTRODUCTORY COMMENTS

This document purports to share progress that has been made in the development of a new health care role. Concern has been expressed by a number of the reviewers regarding the development of this and other similar roles, all of which have come about following the institution of the new GMS contract and the changes in the Primary Care Out of Hours Service. There is a perception that there was a failure on the part of the Executive to appreciate that these changes were likely to create a gap in the provision of service, particularly in the out of hospital environment. Since this gap became evident, there have been a number of initiatives and ventures which could at best be described as knee jerk responses to fill the void. While there may well be a need for Emergency Care Practitioners, it is felt there requires to be further clarity on the role and in particular how ECPs are going to interface with other parts of the service and exactly where they fit in with the other paramedical roles which are currently in place or under development, such as Emergency Nurse Practitioners, Paramedic Practitioners, Physician Assistants etc. There is real danger that such roles may well conflict and create further confusion. It is felt that there is a real lack of clarity with regard to strategy in this area at the moment. This is exemplified by the Government now indicating that they want to look at extending opening hours in general practice shortly after reducing them with the introduction of the new GMS contract.

Provided Emergency Care Practitioners are part of a well thought out strategic approach to Emergency Care, and there are doubts as to whether this is in place at the present time, there is a general feeling that this role should be supported.

Format/Structure

There were concerns regarding the form of the document and it was felt by one reviewer that it would benefit from a complete re-write. The style and level of jargon used are typical of a Department of Health document and there are large tracts of the text which consist of very recognisable terminology with a particular form of ‘spin’ indicating that there will be an inherent level of excellence within the Emergency Care Practitioner role. The College would highlight the section 1.1 and paragraph 4 of section 1.2 as being particularly good examples of this. Perhaps due to the insistence of sticking with this particular format, the grammar and use of language is substandard and, as one reviewer has commented, it is certainly not written in ‘plain English’. We suspect it would be received better by professionals if it was entirely and plainly factual. If this was the case, the document could certainly be shortened.

Specific Comments

Section 1.2. This should be a statement of fact rather than aspirations.

The plan to prevent avoidable A & E attendances or admissions to secondary care is sound, but most recent initiatives which have had this as a stated intention have not been successful and on occasion have had the opposite effect.
Perhaps add some reassurance that Emergency Care Practitioners will not add a further obstacle to accessing Secondary Care if that is what is required.

Section 1.3. It was suggested that the introductory wording in this section could be improved.

It was suggested that this section should also have a list of areas which the Emergency Care Practitioner will not perform.
Further comments in this section were that to obtain proficiency in all areas mentioned may well take longer than anticipated, and it was also felt that some mention should be made under The Scope of Practice of who would provide day to day supervision and where clinical governance responsibilities would lie.

Section 1.5. The last paragraph under this heading describes the extent and breakdown of the academic programme. It should be acknowledged that it is very difficult to be prescriptive on this, and the College feels it should be emphasised that this is what is proposed. It may require further consideration and a number of individuals may take longer than this to achieve competency.

Section 2.1. A recurrent theme among all the reviewers was the concerns with regard to Voluntary Registration. It was felt that Voluntary Registration was fraught with difficulties, and there should be a move towards statutory regulation as soon as possible. It was strongly felt that the timescale for this change should be short, specified and definite.

Section 2.1. There are several references to the autonomy of the HEIs in terms of care or provision. Given that what has been described is a generic course for competency, recommendations should be more robust.

The HEI should be commissioned to provide the necessary curriculum and competence to provide safe patient care and there should be some agreed constraints.

Section 2.4. There does not appear to be any clarity as to who will be responsible for the appraisal and assessment of ECPs and, while it may be premature, it was felt there should be some indication as to how individuals will be selected for training.

The document makes the mistake of quoting jargon – ‘expert communicators who are empathetic in a manner appropriate to a health care profession’. This is bland and meaningless and could surely be improved upon.

Section 2.5. Concern was expressed about the potential variability between different institutions and, while it is recognised that this is probably inevitable, some form of standardisation would be helpful. It was again highlighted that there were concerns regarding the total length of the training programme. Given the varied background of entrants and the range of competencies, it was felt that this timing needed to be increased.

Section 2.6. There is a requirement for clarity as to defined entry criteria from the professional roles - what does ‘appropriately experienced Paramedics and Nurses’ mean?

There is mention of other professionals but these appear to be a secondary consideration, and that may well be interpreted as a discouragement to anyone other than paramedics and nurses.

Section 2.6. The section ‘Other entry routes’ requires greater clarity and explanation. The College was left with no clear idea of what was being alluded to.

Section 2.6. The document refers to Grandparenting rights. There is no explanation of what this is and we have never heard the term before.

Section 2.6. The term ‘APL/APEL’ is introduced. This is the first mention of it within the document; it is not explained and it should be written in full at this point.

Section 3 – Competence framework. This section needs a complete re-write. There is significant overlap, and there has to be a better way found of presenting this data. While the overall clinical material that is covered is for the most part sensible, it is very difficult to go through this section and be able to pinpoint any omissions. The College would suggest it should be displayed in tabular form or as a range of clinical competencies.

SUMMARY

There is a desperate requirement for clarity, not only on the role of the Emergency Care Practitioner, but how this will integrate with existing services and the increasing number of paramedical roles involved in Out of Hours and Emergency Care. It was further felt that there is a requirement for standardisation among HEIs, and a degree of flexibility with regard to the amount of training that is required to produce an appropriate level of trained professions for the requirements of the NHS. It was very strongly felt that a period of voluntary registrations for ECPs should be limited and there should be a progression to the statutory registration at the earliest opportunity. It was felt that, overall, the role of the Emergency Care Practitioner could be supported, provided that role was clearly defined and could be integrated.

Copies of this response are available from:

Lesley Lockhart,
Royal College of Physicians of Edinburgh,
9 Queen Street,
Edinburgh,
EH2 1JQ.

Tel: 0131 225 7324 ext 608
Fax: 0131 220 3939