RCVS responds to EFRACom report and press release

"We are grateful to the Environment, Food and Rural Affairs Committee of the House of Commons for the work it has done in identifying and proposing measures to address threats to the sustainability of the veterinary workforce. There is much that is welcome in the report published today and we look forward to responding in full in due course. 

“We are concerned, however, that one of its recommendations, to establish a new veterinary regulator to which the regulatory functions of the RCVS would be transferred, seems to be based on a fundamental misunderstanding of the current role and functions of the College. 

“The report appears to assert that this reform is necessary because the functions of the RCVS are in conflict with one another, or that it is otherwise undesirable for these functions to be carried out by one organisation. Comparison with the legal sector – in which the regulatory and representative functions of professional bodies were separated by statute in 2007 – strongly implies that the committee considers the same reform necessary in the veterinary sector because the RCVS has similarly conflicting functions, which it does not, and suggests a conflation between professional leadership and representation. 

“Furthermore, the report fundamentally misunderstands the concepts of self-regulation and regulatory independence. In the context of modern regulatory regimes, 'self-regulation' refers to the independence of a regulator from government, not whether a profession makes rules for itself. In this sense most professional regulators, including the General Medical Council, are both self-regulating and independent.

“The press release accompanying the report is more explicit on these points, arguing that the establishment of a new regulator would allow the RCVS to “specialise in continuing to represent the profession’s interests.” To be clear, the RCVS does not represent the interests of the veterinary profession as a whole, nor those of the individual veterinary professionals we regulate.

“While it is true that the RCVS is currently both a statutory regulator and a professional leadership body, we carry out our statutory regulatory function in the public interest under the Veterinary Surgeons Act 1966, and we carry out our professional leadership function in the public interest in line with the objectives in our Royal Charter. There is therefore no conflict between the two functions; indeed, they are complementary, allowing us to take a holistic approach to setting, maintaining and advancing veterinary standards. 

“Our Royal Charter has enabled us to innovate and plug gaps in our aging legislative framework, for example through regulating veterinary nurses and providing quality assurance of veterinary care through our Practice Standards Scheme. Far from detracting from or conflicting with our regulatory function, our professional leadership function, underpinned by the Charter, has reinforced our ability to take action in the public interest where we may not have statutory powers to do so.

“In relation to any suggestion that the RCVS should no longer be the veterinary regulator because it is unduly influenced by the profession through its governance arrangements, we would emphasise that the College has for some time been advocating for legislative reform that would replace its governing Council with a fully appointed board with lay parity, which would remove any risk, real or perceived, of the profession setting and marking its own homework. We are pleased that Defra has adopted this recommendation in full as part of its proposed reform of the Veterinary Surgeons Act 1966.”