Vet Legislation Reform: 3. Assuring practice regulation

RE: Vet Legislation Reform: 3. Assuring practice regulation

Richard Carter — Tue, 20 Apr 2021 14:17:30 GMT

My comments included concerns over the RCVS wanting to assume powers only awarded to groups dealing with criminal behaviour- not meeting U.K. practice standards is not a criminal activity

RE: Vet Legislation Reform: 3. Assuring practice regulation

Arlo Guthrie — Tue, 20 Apr 2021 13:19:35 GMT

Update. I have replied to the consultation representing VetSurgeon.org

Here is what I wrote WRT to section 3

Recommendation 3.1: Mandatory practice regulation

My remarks reflect points raised by veterinary surgeons on www.vetsurgeon.org:

a) It seems inefficient, unwieldy and potentially confusing to the public to have two RCVS practice schemes: PSS and the new practice regulation. One suggestion is that practices should be licensed (regulated) as part of PSS.

b) There is the question of whether vets' registration fees should be used to fund the inspection of businesses which are (largely) no longer owned by vets.

c) There is the concern that the cost of increased bureaucracy will be passed to owners, who are already facing bigger vet bills proportionately than at any time in history. Will the welfare of animals be better served by greater investment in regulation, or by more affordable care?

Recommendation 3.2: Powers of entry for the RCVS

My remarks reflect points raised on www.vetsurgeon.org:

Powers of forced entry would not be a 'good look' for the RCVS, and potentially contribute to the pervasive grumbling fear that veterinary professionals have of the regulator. Surely, therefore, the need for it should first be demonstrated? How many times has the RCVS so far been refused entry to investigate a breach in standards? If none, then surely the case for it has not been made.

Also

a) Concern over why the RCVS needs power of entry when investigating practice standards, because substandard practice would normally pose minimal risk to animal welfare, and even if there is a welfare issue, then powers already exist for the police/RSPCA to enter.

b) Proposal does not make clear who would force entry. Would it be PSS inspectors and would they be prepared to do it?

c) Most importantly, what checks and balances could be put in place to make sure that the powers were being used proportionately and fairly in all cases?

Recommendation 3.3: Ability to issue improvement notices

What is the sanction for failing to comply with an improvement notice? Without clearly stating a sanction, some have remarked that it would be a toothless exercise.

RE: Vet Legislation Reform: 3. Assuring practice regulation

Richard Carter — Thu, 11 Mar 2021 09:08:18 GMT

Actually the RCVS has nothing to do with practice- it is trying to move into this area. The role of the RCVS is to ensure that people working as veterinary surgeons are suitably qualified

RE: Vet Legislation Reform: 3. Assuring practice regulation

Julie Lavis — Wed, 03 Mar 2021 13:24:01 GMT

In terms of policing practice, that is the role of the RCVS. If Inspection is refused then that might have implications for the practice license, e .g 3 points on the practice license, as per driving. I'm assuming right of entry is more of a last resort once reasonable negotiation for a mutually convenient inspection has been refuse.

RE: Vet Legislation Reform: 3. Assuring practice regulation

Bob Russell — Wed, 03 Mar 2021 13:06:05 GMT

I come back to my view that the RCVS will have to employ a police force for any of this to be of any value at all.

Power of entry comes with legal responsibilities and requires checks and balances. I see no evidence of such checks and balances.

Perhaps we should see the scrapping of the PSS and adoption of the VMD inspections. Our first inspection was really constructive, the second was a jobsworth exercise.

RE: Vet Legislation Reform: 3. Assuring practice regulation

Julie Lavis — Wed, 03 Mar 2021 12:32:25 GMT

Oops, last word should be standard. Having trouble editing.

RE: Vet Legislation Reform: 3. Assuring practice regulation

Julie Lavis — Wed, 03 Mar 2021 12:30:38 GMT

Thanks Arlo! When the 1966 Vet Surgeons Act came into effect only vets could own veterinary practices. New legislation gives the opportunity to regulate employer and employee, as before.

As regards the limited license, I am concerned about section 5, 55; "Further, in future there may be an appetite for RCVS council, after due consultation, to introduce limited licensure of overseas veterinary graduates whose degree does not qualify them for a general UK license. This could allow the RCVS to help address workforce shortages without undermining the assurance of stAndrade."

RE: Vet Legislation Reform: 3. Assuring practice regulation

Arlo Guthrie — Wed, 03 Mar 2021 08:41:39 GMT

[quote userid="16318" url="~/001/nonclinical/f/life-in-practice-discussions/29664/vet-legislation-reform-3-assuring-practice-regulation/228870#228870"]What if practices were licensed as part of their PSS scheme? ( after all they have to pay for the inspection anyway)[/quote]

Julie Lavis I wonder if it is just me that thinks this is an interesting / brilliant / genius idea? Could it put the 'practice-owned-by-unnacountable-company' genie back in the bottle? As you say, could be used to ensure good employment standards. I wonder if t was floated by the legislation working party?

[quote userid="16318" url="~/001/nonclinical/f/life-in-practice-discussions/29664/vet-legislation-reform-3-assuring-practice-regulation/228870#228870"]By the way I hate the idea of limited licensed vets, a vet is a vet or is not a vet, MRCVS only, other wise too vulnerable to exploitation and bullying as a "second class vet".[/quote]

Not sure if there was enough detail in the proposal to understand exactly how limited license would work in real life. But the main aim seemed to be greater access for people with disabilities, and I doubt they would be a victim of bullying in this day and age. But I am still sitting here scratching my head how it would work. 'You have a disability, so you are limited to doing flea checks'??? Same question about overseas graduates. Again, not sure about bullying, but I suspect it could leave them open to exploitation (ie being paid pennies)

RE: Vet Legislation Reform: 3. Assuring practice regulation

Julie Lavis — Wed, 03 Mar 2021 01:08:21 GMT

What if practices were licensed as part of their PSS scheme? ( after all they have to pay for the inspection anyway). Part of PSS involves requirement to have an employment contract, if the RCVS is serious about the factors they have identified as impacting fitness to practice ( e.g. Affecting mental and physical health in mind matters etc) they could define healthy working environment, powers of entry allow inspection and if vet suspended / investigated found to have been working under undue pressure then practice license holder can be held responsible fined, refused license. This idea of a vet led team has some merit but if the working conditions, (personal, equipment, training) are lacking and not under the control of the vet but their employer, to not have consequences for the employer is ridiculous. Employers will just demand more replacement vets ( but that is what the "licensed" vet position is all about , importing "less" qualified vets) so they can churn through their staff with impunity. Just a few late night thoughts. By the way I hate the idea of limited licensed vets, a vet is a vet or is not a vet, MRCVS only, other wise too vulnerable to exploitation and bullying as a "second class vet".

RE: Vet Legislation Reform: 3. Assuring practice regulation

Richard Carter — Sun, 28 Feb 2021 07:21:24 GMT

I’ve always thought the practice standards scheme is a mixture of bad workmen blame their tools and for those people who get a thrill out of collecting gold stars from the teacher- got nothing to do with being a good ethical practical vet

it is also a convenient way of reducing competition from disgruntled vets who might have set up in opposition.

My career started in rural Africa with a van and a box of medicines and a rope - and we did a pretty good job of spaying on kitchen tables or te bonnet of said van so having flashing beeping machines with qualified people now more interested in completing paperwork is not actually progress and I feel real sadness for the vets who can’t do something because the right x ( wind, water?) isn’t there.

RE: Vet Legislation Reform: 3. Assuring practice regulation

Nick Jackson — Sat, 27 Feb 2021 15:51:40 GMT

[quote userid="2100" url="~/001/nonclinical/f/life-in-practice-discussions/29664/vet-legislation-reform-3-assuring-practice-regulation/228806#228806"]Am I being really thick ... I thought there was only the PSS! [/quote]

No not being thick, there is just the PSS at the moment. However in the LWP document they discuss that there would be a separate compulsory regulation scheme to compliment the PSS ... which seems to be a little less than sensible, not to mention confusing for the public.

RE: Vet Legislation Reform: 3. Assuring practice regulation

Arlo Guthrie — Sat, 27 Feb 2021 10:14:10 GMT

I've added a summary of the discussion so far to the original post appearing at the top of each page.

Nick Jackson That final point you made is a really interesting one. Is it fair that the cost of maintaining a scheme to inspect businesses should be shouldered by the employees of those businesses?

[quote userid="18277" url="~/001/nonclinical/f/life-in-practice-discussions/29664/vet-legislation-reform-3-assuring-practice-regulation/228570#228570"]There seems to be a lot of talk about how they may think about regulating practices, although this seems ill thought through (having 2 standards schemes because they are so wedded to the current?!). [/quote]

Can I ask what you mean by two practice schemes. Am I being really thick ... I thought there was only the PSS!

Anyone else got anything else to add?

RE: Vet Legislation Reform: 3. Assuring practice regulation

Nick Jackson — Mon, 15 Feb 2021 13:37:45 GMT

[quote userid="2100" url="~/001/nonclinical/f/life-in-practice-discussions/29664/vet-legislation-reform-3-assuring-practice-regulation/228572#228572"] in the report it says other regulators rarely have this power[/quote]

You are right, I think I was writing this after having got into reading a different section where what I said applies.

I Still dont see how power of entry should be required, the scenario they are talking about poses minimal risk to animal welfare (though might to the standing of the profession). However if they think it does pose a risk to animal welfare as Bob says, the process exists already and doesnt require RCVS involvement.

If they are looking to emulate the QCC in human medicine there should be a routine process of inspection regardless, and I would expect really that it would be spun out of the RCVS, if for no other reason than to correctly apportion the cost of running it. Given most vets are no longer business owners, or responsible for the buildings they work in, I certainly dont expect to fund this work through my RCVS members fee.

RE: Vet Legislation Reform: 3. Assuring practice regulation

Bob Russell — Mon, 15 Feb 2021 09:31:36 GMT

I presume the RCVS would rely on PSS inspectors or some equivalent demanding entry. Would they be willing to do this? In effect this would require a 'police' force.

The only situation where emergency access is likely to be required would be when there is evidence for a serious welfare issue. This is already covered by existing regulations and (presumably) would involve the RSPCA and the Police.

This appears to be a power grab and another bully boy tactic just for the sake of it.

RE: Vet Legislation Reform: 3. Assuring practice regulation

Arlo Guthrie — Mon, 15 Feb 2021 09:14:03 GMT

[quote userid="18277" url="~/001/nonclinical/f/life-in-practice-discussions/29664/vet-legislation-reform-3-assuring-practice-regulation/228570#228570"]Firstly - thanks Arlo Guthrie for making these threads - hopefully a usefull sounding board for opinions. [/quote]

Nick Jackson My pleasure, and that's what I hoped!

[quote userid="18277" url="~/001/nonclinical/f/life-in-practice-discussions/29664/vet-legislation-reform-3-assuring-practice-regulation/228570#228570"]The section regarding the requirement for power of entry says almost nothing about why they want this power other than that other regulators have it. I know this makes a number of people uneasy and would really appreciate a good logical reason for this, they even imply they wouldnt use it in the report.[/quote]

Hmm - in the report it says other regulators rarely have this power, but the reason that the RCVS wants it is because:

However, where there are allegations that a veterinary surgeon has breached paragraph 4.3 of the RCVS Code of Professional Conduct, which states that ‘veterinary surgeons must maintain minimum practice standards equivalent to the Core Standards of the RCVS Practice Standards Scheme [PSS]’, powers of entry would be useful. This is because, if a veterinary surgeon refuses entry, it is extremely difficult, if not impossible, for the RCVS to investigate allegations of this nature.

That seems reasonable enough, but the first question that comes to my mind is how many cases there are each year where veterinary surgeons have been subject to an investigation about practice standards and have refused entry.

I think there is also a question of proportionality which needs to be considered. But this is something I think is most relevant to the issue of disciplinaries, so I am going to raise it first in that thread.

RE: Vet Legislation Reform: 3. Assuring practice regulation

Nick Jackson — Sun, 14 Feb 2021 14:38:40 GMT

Firstly - thanks Arlo Guthrie for making these threads - hopefully a usefull sounding board for opinions.

I this this section is really pertinent to the future management of the profession given the level of corporate control currently present and the impacts this has on service provision.

I have a few thoughts on the proposals.

The section regarding the requirement for power of entry says almost nothing about why they want this power other than that other regulators have it. I know this makes a number of people uneasy and would really appreciate a good logical reason for this, they even imply they wouldnt use it in the report.

There seems to be a lot of talk about how they may think about regulating practices, although this seems ill thought through (having 2 standards schemes because they are so wedded to the current?!).

They dont seem to be advocate any powers of enforcement other than issuing improvement notices, a little toothless if you ask me. Which makes this all sound like a good way increasing bureaucracy and cozying up with corporates.

Finally - what will constitute a practice - an individual site? A group of sites? A whole corporate body?

Really interested in anyones thoughts