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FHCS response to Equality and Excellence: Liberating the NHS Consultation


The Federation is a UK-based body providing a collective voice for science in the health service to government, other health care professions and to the public. It is a representative professional forum covering the three main streams within Healthcare Science namely the life sciences, the physiological sciences, and physics & engineering.


The Federation understands the key concepts around commissioning particularly during a challenging financial climate. The movement to GP commissioning will bring significant challenges both in transition and full implementation.

Some of the challenges that will impact on diagnostics may bring significant structural change in how Health Care Science is delivered in the future. One area that requires further clarification concerns intelligent commissioning and ensuring the appropriate quality standards are created to prevent negative patient impact and the potential for inferior provider delivery.

Failure to fully explore the ramifications of this can be reflected in laboratory services where the lack of understanding of the complexity in delivery, cost and quality around complex, interpretive tests will result in significant gaps in the quality of the patient experience. It will also be a considerable challenge in commissioning specialist services where low volume, high complexity tests are carried out nationally or regionally. It is unlikely that commissioning from GP Consortia as described will identify the main risks to the quality of the delivery in this area of testing.

There is the potential to unbundle tariffs as a consequence of the delivery of the diagnostic agenda and the commissioner having a choice of diagnostic providers. There is anxiety that commissioners may ‘cherry pick’ particular services without addressing the infrastructure required to deliver 24/7 laboratory services. Potentially making local NHS providers unsustainable and leaving a significant gap in local service delivery. This is also relevant to smaller professions whose activity is included in other care pathways. Clinical Photography for example is included in national Cleft Lip and Palate audits, but the costs are not identified in an individual tariff. If unbundling is required it needs to reflect the level of staff required to deliver potentially high-risk procedures in the community without the normal support, which is easily accessible in a secondary care setting.

How scientific services using shared facilities will be delivered when coordination is required across many GP consortia. Care will be needed to ensure that scientific services, which are most frequently linked to tertiary referral centres are themselves supported by commissioning processes that operate on appropriate scales. Examples would include PET-CT imaging, rehabilitation engineering and radiotherapy treatments, often provided in centres serving approx 1million people, and hence requiring coordination across many GP consortia.

The Federation has concerns over the quality standards for point of care services from commissioning to production of a final result and its interpretation. The Federation will be producing a report, recommendations and guidelines for safe and effective point of care practice as the overarching body representing the healthcare science, intended for all healthcare staff engaged in these activities. This will cover advice on the introduction of point of care services (either as a replacement or adjunct to laboratory testing), the selection of appropriate in-vitro diagnostic devices, the training of non-laboratory based staff in their use and the appropriate quality control procedures to help ensure safe practice for patients.

There needs to be a level playing field for private vs. public contracts. The Federation has concerns that training costs are often not factored in to private bids for services. Whist the white paper suggests training costs will be shared across all providers it is likely this will be difficult to instigate, particularly if providers are small in size and costly to monitor.

The proposed introduction of best-practice tariffs, sothat providers are paid according to the costs of excellent care, can be an excellent mechanism for promoting uptake of innovative procedures. An immediate example with current public interest would be advanced radiotherapy (IMRT and IGRT), where implementation has been hampered by lack of local funding for the additional clinical and scientific work required.

Training and Workforce issues

In general we welcome the proposal for the professions to have a leading role in deciding the structure and content of training, and quality standards. As new models of education and training are developed for all those working in healthcare science, we believe the role of professional bodies in curriculum development and quality assurance should be strengthened. The Federation has concerns as to whether education and training of the NHS workforce will be a priority as the changes to the NHS structure take place.

Given the current uncertainty as to whether the Modernising Scientific Careers (MSC) project will be fully funded following the outcome of the Comprehensive Spending Review and demise of the SHA’s, there is concern that the Department of Health continues to push its agenda to redesign existing educational pathways is having a detrimental effect on training. In particular there has been only slow progress towards introducing the system of regulation envisaged under MSC with the result that early implementers of MSC are being trained in a manner that is not consistent with the existing requirements for regulation.

The proposal for healthcare employers to agree funding for workforce development and training may lead to difficulties in planning and delivering training for scientists needed by the service in small numbers of highly specialist areas. The existing supernumerary scheme for clinical scientist training that is mirrored in the current proposals for MSC and operating at SHA level to provide the necessary critical mass has been extremely successful. We believe that similar regional or national coordination of both workforce planning and trainee funding will be essential for healthcare science.

Specialist training has been significantly reduced under MSC, potentially leading to a less experienced practitioner at the end of the training period than is currently the case. This in turn poses significant risks to patient safety. We note that the UK has a number of HEIs, which currently provide medical physics and clinical engineering degree courses with a worldwide reputation. These high quality courses require a mixture of full-time and part-time participants to be cost-effective. We are concerned that the needs of Higher Education Institutes are not being met by the current proposals for MSc degrees spread over three years, and that we risk the loss of considerable expertise in delivering training to healthcare scientists, together with established research links. The latter are crucial in ensuring that we continue to attract high quality graduates, for whom many other potential career paths are available.

The Federation has, over a number of years, made its concerns known over the slow progress made by the Department of Health to regulate a number of its member groups despite these groups having voluntary registers in place. Voluntary self-regulation, when administered by a single, professional body, is often thought to be enough to protect the patients. However our member bodies have a substantial amount of evidence suggesting that, in their case, voluntary self-regulation is not as effective as statutory regulation. We therefore believe that statutory regulation should be introduced for those professions as soon as possible.


We welcome the clear commitment to the promotion and conduct of research as a core NHS role. It is an essential activity if we are to increase the quality and productivity of the NHS. We believe that healthcare scientists are key players in this process. To this end we note the importance of research training as part of the career scheme for healthcare scientists, and the recognition of development work as a core component of scientific activity.

Quality and Safety

The White Paper lays proper emphasis on patient safety and we note the important role many healthcare scientists have in ensuring safe and effective use of medical technology, particularly the use of point of care devices. The shift of services outside of hospitals means that more staff are likely to be employed in community settings and community services. The federation is surprised by the lack of detail as to how standards in the community setting will be monitored. It is surprising that there is no mention of regulation and the Health Professions Council as a vital component of ensuring high standards for the entire healthcare science workforce. As mentioned previously, we believe that all groups of healthcare science practitioners (as defined under MSC) should be included in a system of statutory regulation, linked to completion of accredited training programmes.

The strengthening of the role of the Care Quality Commission and their inspectorate is also welcomed, particularly for safety critical areas such as radiation protection and medical equipment. However, we have concerns about the future of the Radiation Protection Division of the Health Protection Agency, and the specialist medical imaging evaluation centres (IMPACT and KCare) formerly supported by NHS PASA.

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