Policy responses and statements
- Name of organisation:
- Department of Health
- Name of policy document:
- Competence and curriculum framework for the medical care practitioner - a consultation
- Deadline for response:
- 10 February 2006
Background: This document outlines the proposed Competence and Curriculum Framework that sets the standards of the education, training and assessment of MCPs to enable qualification from a UK higher education institution.
The Framework outlines the knowledge, skills and core competences expected at the point of qualification. Although it is recognised that MCPs may develop areas of special interest and expertise, they will be required to maintain this broad competence throughout their careers.
In particular, the Department of Health invited comments with respect to:
- the Curriculum Framework for the MCP as the basis for the development of educational programmes
- entry routes to the MCP programme
- the core competences at qualification
- the core clinical skills which the MCP needs to demonstrate
- the core clinical conditions which the MCP will meet in practice and the level of competence required
- arrangements for teaching and supervision
- methods of assessment, pre and post registration and national support structures
- the title for the new role.
eCOMMENTS ON
DEPARTMENT OF HEALTH
COMPETENCE AND CURRICULUM FRAMEWORK FOR THE MEDICAL CARE PRACTITIONER - A CONSULTATION
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 medical care practitioner.
The College welcomes this early consultation as the development of this new health professional role is important to the workforce strategy of the NHS, providing an opportunity for competent life science graduates to contribute to patient care. It is important that clinical standards and patient safety are protected through rigorous assessment and regulation procedures, and that the complementary roles of physicians and medical care practitioners are understood fully by clinical staff and patients.
QUESTION 1 (PAGE 8)
Do you believe that the practitioner should have access to a prescribing formulary identical to that of their supervising physician to be used within local agreed guidelines?
All practitioners should have potential access to the same formulary, but prescribing rights should be restricted to individual’s documented competency and used within locally agreed guidelines.
QUESTION 2 (PAGE 18)
What are your views on the proposed standard of proficiency as set out in the preceding sections, which focus on competence, procedural skills and core clinical conditions, in terms of the level at which the practitioner will practice upon registration?
The College believes there would be benefit in styling the curriculum in a similar way to the Foundation and Acute Medicine curricula, listing the core clinical conditions by patient presentation rather than diagnosis eg headache.
The College has the following specific comments about the procedural skills and core clinical conditions as follows:
(a) Missing from the lists are:
(b) Why restrict musculoskeletal manipulations to shoulder dislocation?
(c) Which type of nasogastric tube insertion should be included?
(d) The balance of diagnostic and management roles seems weighted more heavily towards diagnosis. Is this intentional?
(e) The matrices offered in section 2.6 would benefit from further clarity eg in 2.6.2 it appears that MCP are to be expected to treat but not diagnose stable angina, whereas the reverse is true of unstable angina. The rationale for such an approach requires expansion.
QUESTION 3 (PAGE 24)
Would you agree that there should be a period of 'probationary practice' post academic qualification and prior to formal registration as an MCP?
Yes, it would be helpful for trainees to have a period of “probationary practice” immediately post academic qualification to demonstrate that knowledge and skills acquired during training can be applied to clinical problems.
QUESTION 4 (PAGE 24)
If you agree that there should be this period, how long should it be and what should be the outcomes?
Up to a year would seem reasonable, with provision for shorter periods according to competences and experience brought from previous roles. The outcome of this period should be a formal assessment by the supervising physician. The College is concerned about the capacity of the NHS (doctor time and clinical caseload) to provide adequate practical experience to support the training, supervision and assessment of these “probationers”, given existing responsibilities for trainee physicians and the training and assessment of nurses and other health professionals in extended roles.
QUESTION 5 (PAGE 24)
During this period would you agree that the practitioner should have their own caseload?
The College understands that MCPs will operate under the supervision of physicians and to their level of competence. This may include their own caseload in the same way as a junior doctor or staff grade has a defined caseload under the supervision of their consultant.
QUESTION 6 (PAGE 24)
During this period would you agree that the MCP should be able to refer on to other practitioners including hospital consultants, therapists and other specialist medical services?
It would seem reasonable for MCPs to have similar referral rights to PRHO level doctors, according to their level of competence, under protocols agreed by local physicians.
QUESTION 7 (PAGE 26)
Would you agree that arrangements need to be put in place to assimilate practitioners who meet the competences of the MCP into the regulatory process?
A clause to enable equivalence assessment would be welcome, if challenging, to implement to ensure standards are consistent across the NHS. Clearly, experienced practitioners, particularly from other health systems, may be permitted greater clinical independence but only after assessment by the supervising physician. Grandfather clauses exempting applicants from assessment would be dangerous.
QUESTION 8 (PAGE 26)
Who should be responsible for this?
The organisation responsible for the register should set the standards and approve the assessment methods, utilising specialist advice from the Colleges. This would include advice for residual training for those failing their assessments and fast tracks to regulation for those with APEL and demonstrable competences. Colleges would also have a role in quality assurance of local training and assessment procedures.
QUESTION 9 (PAGE 26)
Do you think that the above proposals regarding the APEL process provide sufficient protection for public safety whilst not being too restrictive?
Yes, if robust assessment tools are available.
QUESTION 10 (PAGE 30)
What are your views on the proposal for a single national assessment for the profession?
As MCPs are likely to be in high demand and may be highly mobile, it is essential that a single framework applies across the UK.
QUESTION 11 (PAGE 30)
The assessment of professional examinations through either an examination board or a professional body is the usual route prior to regulation. However on becoming part of a statutory register there is a requirement for qualifications to be independently assessed and quality assured and therefore requires professional body examinations to be embedded within the HEI sector. Should the regulator be the sole assessor of educational programmes?
The Medical Royal Colleges have a key role in assessing the (continuing) suitability of educational programmes in liaison with the regulator. This will provide the necessary specialty-specific expertise.
QUESTION 12 (PAGE 30)
The steering group members who have written this document have the combined expertise to validate educational programmes for the role in the interim period. What are your views?
This is a pragmatic approach, and the team would benefit from a UK perspective through representation from the devolved administrations. The team may also benefit from additional experience of validation.
QUESTION 13 (PAGE 31)
Periodic re-registration through the passing of a re-accreditation examination is a relatively new process for healthcare professions. Do you foresee any issues with the introduction of this process?
Re-registration is important and need not be in a traditional examination format. Knowledge should be updated and assessed, and computer based tests may offer a cost-effective solution, if expensive to develop and validate initially. This will complement CPD recording and local practical assessment of procedural skills and patient management. Remedial training opportunities will be needed for those in difficulties. There is no clear organisational structure proposed for the postgraduate training for MCPs and it may be helpful to incorporate them within the postgraduate medical deaneries, ensuring a UK approach to standards in line with that offered for doctors. CPD support could be provided by the Medical Royal Colleges.
QUESTION 14 (PAGE 31)
What are your views on compulsory periodic re-assessment?
The College welcomes the concept of regular re-assessment for MCPs, given their proposed role in diagnosis and patient management. This is in line with plans for doctors and other healthcare professionals.
QUESTION 15 (PAGE 31)
Do you have any suggestions regarding how this periodic re-assessment will be funded whilst remaining independent?
On the principle that the beneficiary pays (a principle adopted by PMETB for postgraduate medical training), it could be jointly funded by the employer and the MCPs themselves.
QUESTION 16 (PAGE 33)
This list is not exhaustive, but do you think that there is a core theoretical knowledge area that is missing?
Understanding of patient safety and clinical governance requires emphasis.
QUESTION 17 (PAGE 33)
What is your opinion of the weighting that should be given to each core theoretical knowledge area ie what are the priority theoretical knowledge areas?
The directly clinical components should be given greater weighting - anatomy, biochemistry, histology, immunology and microbiology, pharmacology and therapeutics, physiology and pathology.
QUESTION 18 (PAGE 34)
Do you think it is appropriate that until the regulatory body is established that the accreditation function be carried out by a panel drawn from the Curriculum Framework and Competence Steering Group, the MCP National Programme Board and participating HEIs?
If not, what alternatives would you suggest?
MCPs are already with us and the regulatory body will take time to establish, especially if statutory powers are required. The above proposal seems sensible to allow rapid piloting of an approach that can be refined and transferred to an independent regulator in due course. Panel members should also be drawn from all the three Royal Colleges of Physicians in the UK and, for consistency with other groups, should include lay members.
QUESTION 19 (PAGE 36)
The issue of the eventual title of the role has been contentious. Ultimately, the title should be one that the public are able to recognise as a descriptor of the role. The title is not a beauty contest and neither should it be a descriptor of 'rank' in a team. Do you have a suggestion that meets the needs of the patient and one that the profession will be happy to adopt?
The College urges the Steering Group to reconsider the title of the role, as the use of the words medical and practitioner will be very confusing and may even mislead some patients. This is the firm view both of our Lay Group and of our Council. MCPs are not fully trained doctors and work, under the supervision of physicians, in restricted roles appropriate to their experience and competence. The term ‘Physician’s Assistant’ better describes their role within the multi-disciplinary team. Other terms which improve on MCP include ‘Medical Care Associate’ and ‘Physician’s Associate’.
QUESTION 20 (PAGE 38)
Do you anticipate that the proposed timeframe is adequate?
It will be extremely challenging to complete the curriculum and pilot assessment tools to accredit MCPs by 2007. However, the College agrees that this should be the target timeframe to secure national standards and protect patients and confidence in this new health professional role.
QUESTION 21 (PAGE 38)
Have you any further comments regarding the process, the document and the role?
The College, based in Scotland but with Fellows and Members working across the UK, is all too aware of the importance of UK consistency in the framework for the training assessment and regulations of MCPs. This will protect standards and support safe and sensible recruitment and retention strategies.
It would be helpful to have more explicit guidance within the curriculum about the basic level of competence expected from all MCPs after registration regarding diagnosis and patient management for general medical conditions (including acute care). Clearly, over time and with experience, individuals may develop different levels of expertise in specialist areas and their responsibilities will be managed through local training and assessment.
Some clarity around the CPD requirements for this group would be helpful (the consultation document focuses on re-accreditation rather than CPD).
Although the College agrees with the 2007 target to provide a framework for standards and training, there is concern abut the practicality of this and the funding that may be required to ensure success.
Early experience of PMETB has demonstrated the costs and time pressures of delivering a new framework for training, whereas this project considers training, assessment and regulation. Is the Department of Health (via employing Trusts and Boards and Deaneries) prepared to underwrite the financial risk?
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
[10 February 2006] |
