From the proposed consultation questions it appears that issues of concern to practitioners and employers may not be covered.
The question
“All non-medically qualified public health ‘specialists’ currently on the UK Voluntary Register for Public Health Specialists should instead be placed on a Statutory Register. The wider Public Health workforce (i.e. those not eligible for inclusion on a Public Health Specialist register) should be subject to a self-regulation register.”
We understand why non-medical public health specialists should sit with medical public health specialists, but where does this leave other public health practitioners?
The terms of reference clearly state that one of the purposes of the review is
- to indicate a policy direction for defined specialists and for the practitioner workforce, but not address issues related to these workforces in their entirety;
- indicate a policy direction on a common pathway to registration, but not address this issue in its entirety;
I cannot see how the narrow question can lead to any meaningful answers as to how these issues can be taken forwards
I am worried that the views of a wider public health based workforce (and in our case we work in Sexual Health), will not be able to be expressed adequately .
Sexual Health Advisers work in both GUM and the wider community often in a Public health context. Although a majority of our members are Nurses, a significant percentage is not and come from varying backgrounds.
This DOH/SSHA document from Anne Mcnall highlights the work undergone so far and the issues that have led to some of this work and our PH work context; http://www.ssha.info/briefing-paper-sexual-health-advising-developing-the-workforce/
I had been under the impression that the review was going to take a clear look at practitioners and cover some of the issues that we had previously worked with the UKVPHR on, to do with assisting in developing standards and looking at how Professionals working in a PH context who are not registered or regulated could be covered.
The content of the review doesn’t appear to fit the original remit of the UKPHR, which was to give the public protection by ensuring a level of accountability through the establishment of a regulatory ‘home’ and professional recognition for those who work in public health. By only focusing on the ‘specialist’ end of this workforce, (many of whom hold dual registration elsewhere such as with the GMC or GDC, which provides at least some level of accountability) the greater majority of the public health practitioners (who are less likely to be hold a separate registration) who work mainly unrestricted with no professionals guidance, accountability, code of ethics, agreed standards, etc, all of which should be in place to safeguard the public. To further compound this issue, many of these practitioners are working in positions of responsibility including managing programmes and people, resulting in an increased probability that the impact of any unsafe (or even just poor) practices undertaken could be far reaching.
I fail to see how the review in its current format will contribute to ensuring the issues above can be taken forwards.
The purpose of what the review is trying to achieve is not clear in its current guise of focusing on should we or should we not have a joint register for different categories of specialists. Clarity on this point is urgently needed. I am concerned that a Stakeholder such as SSHA was not involved in discussions or invited to stakeholder events and have found out ‘by accident’ that they can engage.
By engaging stakeholders in the consultation, costs and time would have been greatly reduced but perhaps more importantly, those people who are familiar with the questions under debate as well as the wider regulatory issues (in addition to having a good understanding of the matter in relation to their specific workforce and a large wealth of knowledge and experience) could have contributed greatly to the consultation.
Jamie Hardie
SSHA President