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LWP update 3: revalidation and limited licensure

During July and August, Vet Record is publishing a series of features about the key recommendations contained in the recent report of the RCVS Legislation Working Party (LWP), from some of those who were directly involved in making them. In the third of this series, RCVS Past-President Amanda Boag (pictured below) discusses the LWP’s recommendations around revalidation and limited licensure. 

Original article: reproduced with the kind permission of the Vet Record 


Amanda Boag, RCVS Vice-PresidentOne of the Legislation Working Party’s (LWP’s) key recommendations is that any new legislation should give the RCVS the ability to introduce a revalidation scheme in future, if this were judged to be appropriate. Revalidation schemes are used in other health professions and are an important component of assuring quality of care for the public. In the same way that revalidation of doctors helps to ensure patient safety in the human healthcare setting, such a system in the veterinary profession would help to uphold standards of animal health and welfare and public health.

Any detailed proposal would need to be shaped to fit the veterinary profession and agreed by RCVS council, but the LWP agreed that, in principle, this was a power that should be available to a regulator.

As far back as 2007, a Department of Health report proposed that all statutorily regulated health professions should have arrangements in place for ‘revalidation’. This is to ensure not only that health professionals remain up to date, but also to demonstrate that they continue to meet the professional standards of their professional regulator as they are now, and not just at initial registration. The RCVS acknowledged this in its 2013 First-Rate Regulator report, which noted: ‘Most regulators already have a role in ensuring that, once registered, registrants remain up to date with evolving practices and continue to develop as professionals.’

Revalidation first aims to give assurance that individual healthcare professionals are not just qualified, but safe. Second, it aims to help identify any concerns about a professional’s practice at an early stage, allowing support for that professional to be put in place. Third, it aims to raise the quality of care for patients by making sure all licensed professionals engage in CPD and reflective practice.

Under the Veterinary Surgeons Act (VSA) 1966, once a vet registers for the first time, they can continue to be registered for the whole of their life (providing they pay their retention fee and are not removed due to disciplinary measures). There is no requirement to revalidate as there is with other professions. The LWP concluded that this does not represent best practice in terms of upholding standards or public assurance, and recommended that the RCVS be empowered to introduce a system of revalidation in future, should RCVS council decide to do so.


Revalidation: the General Medical Council’s model

The General Medical Council (GMC) became the first UK health regulator to implement a system of revalidation. Its five-year revalidation cycle takes into account a local evaluation of a doctor’s practice through annual appraisal. The appraisal is carried out by an experienced independent doctor, and then referred to a ‘responsible officer’ who has a statutory responsibility for making a revalidation recommendation to the GMC. The responsible officer makes a recommendation about the doctor’s fitness to practise to the GMC based on the outcome of the doctor’s annual appraisals over the course of the five years, a portfolio of supporting information that meets the GMC’s requirements, and whether there are any outstanding concerns for any part of the doctor’s scope of work. Following the responsible officer’s recommendation, the GMC decides whether to renew the doctor’s licence to practise.


Mandatory CPD

The First-Rate Regulator report also noted that: ‘CPD is a requirement for all professionals wishing to register with the health professional and legal services regulators.’ However, the VSA does not give the RCVS power to enforce this requirement by any means other than the disciplinary process. Vets are currently asked to certify that they have satisfied the CPD requirement as part of the annual renewal process. However, if they do not complete their CPD, the RCVS has no power to refuse renewal of registration. The only possible route to address this is through the full disciplinary process during which time the veterinary professional can continue to practise.

The LWP felt that it was unacceptable for vets to be able to practise without keeping their knowledge up to date, and that the college should therefore be able to reserve the right not to renew registration if CPD requirements were not met.


Limited licensure

A limited licensure scheme would allow an individual to be licensed to undertake some, but not all, of the activities that could be considered to be acts of veterinary surgery.

The LWP also explored the concept of ‘limited’ or ‘restricted’ licensure. In limited licensure schemes, a suitably qualified individual would be licensed to undertake some, but not all, of the activities that could be considered to be acts of veterinary surgery. In principle, the limitation could range from an individual being restricted from undertaking a specified act or area of practice, through to only being licensed to undertake a specific procedure or area of employment.

Under the VSA, there is no provision for UK-qualified vets to operate under limited licensure. The general licence for veterinary surgery is considered an international standard (particularly for the purposes of certification, for instance in international trade of animal and animal products). Currently, there is limited appetite for general introduction of limited licensure for domestic graduates, but this may change in future.

Furthermore, in future, there may be an appetite for RCVS council, after due consultation, to introduce limited licensure for overseas veterinary graduates whose degree does not qualify them for a general UK licence. This could allow the RCVS to help to address workforce shortages without undermining the assurance of standards. For instance, the RCVS could be confident that an overseas-qualified vet was competent to work in one or more UK sectors by virtue of their qualification, but less confident of their competence to work in general practice; they could, therefore, be given limited licensure if their skills fitted a sector that was under acute shortage, without the risk that they might move sectors once registered. The LWP recommends that the RCVS be given the power to implement a limited licensure scheme should RCVS council decide that it was needed.

Finally, and importantly, in addition to that general recommendation, the LWP agreed a specific recommendation to permit limited licensure for UK graduates where disability prevents them from being able to undertake all aspects of a veterinary degree and veterinary practice. For instance, an individual may not be able work in practice due to a disability, yet still be able to teach, undertake research, work in pathology, veterinary regulation, politics or policy. Limited licensure could permit such candidates to complete the relevant education for a branch of veterinary surgery, and allow them to become members of the RCVS. The RCVS Diversity and Inclusion Working Group will be exploring detailed proposals in due course, but it would require amendments to legislation to implement any such reforms.

August 2020