More RCVS red tape

Re: More RCVS red tape

Evelyn Barbour-Hill — Wed, 07 Jul 2010 14:17:40 GMT

[quote user="Anthony Todd"]I'm sure the annual confirmation requirement must be there, the RCVS wouldn't just add it on[/quote]

Re: More RCVS red tape

Anthony Todd — Wed, 07 Jul 2010 08:21:59 GMT

I've been right through the BERR Guidance document and I can't find anything about repeating anything annually.

The principle makes sense really if you've ever tried to sort something out with a large organisation.

I wonder if BT ticks a box every year though?

I'm sure the annual confirmation requirement must be there, the RCVS wouldn't just add it on, so could someone more diligent than I tell me where it is.

The doc. is only 56 pages long so it should be easy to find.

Re: More RCVS red tape

J G Wray — Thu, 24 Jun 2010 13:05:23 GMT

[quote user="Jonathan Wray"]I see 386 people are being removed from the Register for non-payment of fees. This is down from 616 under the old system[/quote]....[quote user="Jonathan Wray"]386/22000 = 1.75% or a 98.25% success rate this year. Well done RCVS. [/quote]

Mea culpa I have done the RCVS a disservice. I see from "RCVS facts", a blinding read, that last year there were 23800 retention fees so the success rate in obtaining the fees was 100- (100*(616/23800)) = 97.4%, but this year, because registrations go up approx 500 per year it is 100- (100*(386/~24200)) = 98.4%

This is even better than I suggested.

Fantastic job RCVS!

Now, why are they changing the system?

Puzzled of Basingstoke

Re: More RCVS red tape

salome2001 — Tue, 22 Jun 2010 23:17:14 GMT

if HMRC are content to have my home address as my principal place of work (as a self-employed locum vet) then what the hell is the problem with it?

"Oh, we can sort something out if there are exceptions" say the RCVS.

Right. So now I not only have to tick their bloody box/ return their envelope just to stay on the roll (even if I've paid the fee), I also have to sit on hold to belgravia house going through ten departments until I find sometone with half a brain who can make my home address my contact address.

I think I'll call them at about 12.00, after running my 2-year old ragged all morning with no nap, right about the time he's ravenous for lunch. that way there should a be a satisfying screaming tantrum in the background to give the RCVS lackey some idea of how much I really, really want to have to call them...

Re: More RCVS red tape

Bob Russell — Tue, 15 Jun 2010 17:11:47 GMT

The RCVS needs to start learning the lighter touch of government. We have been crushed by the nonsense legislation created by 13 years of control freaks. It is now time for us all to get used to taking responsibility for ourselves.

The new government is already throwing out pointless regulation on a daily basis. The powers that be at the RCVS need to start thinking independently and making sure there is a genuine need for changes in the rules or any need for that particular rule at all.

Re: More RCVS red tape

james hunt — Tue, 15 Jun 2010 16:27:49 GMT

[quote user="Evelyn Barbour-Hill"]

Who is to say that a "service provider" (hideous term) is each individual veterinary surgeon - rather than a practice, as any rational ordinary person would suppose?

[/quote]

I think you've hit the nail on the head Evelyn, and the introduction to the draft regulations supports the notion that the PRACTICE is the service provider

2.—(1) In these Regulations “service” means any self-employed economic activity normally provided for remuneration (as referred to in Article 50 of the Treaty).

Given that assistants are employed and cannot therefore be engaged in self employed economic activity, it would appear that all employees are immediately exempt from the regulations. Practice owners may still be obliged to follow these regulations unless the practice is a PLC or some such?

Re: More RCVS red tape

J G Wray — Tue, 15 Jun 2010 15:49:14 GMT

I see 386 people are being removed from the Register for non-payment of fees. This is down from 616 under the old system.

A quick scan tells me that there are lots of non-Anglo surnames and women. The reason why they are not there is immaterial.

Could the RCVS be asked to repost these names with an analysis of where they qualified, age and gender?

If RCVS could be encouraged to approach these type of vets first, i.e. those with the same profile in this years register, they might have even fewer probs next year.

This would be a systematic, rather than scatter gun approach.

Ooooops sorry, I forgot. We're getting a new system next year. It'll be interesting to see what the numbers are then.

386/22000 = 1.75% or a 98.25% success rate this year. Well done RCVS. I suggest you change nothing or if you have to spend money, target those like the this year's 386.

JGW

Re: More RCVS red tape

Anthony Todd — Tue, 15 Jun 2010 00:33:39 GMT

[quote user="Evelyn Barbour-Hill"](perish the thort).[/quote]

Love it. I hope the spelling was deliberate, and I define a "thort" as a thought which contains a deeper, cynical, sarcastic, or opposite implication, sort of oxymoronic as in "Microsoft works".

Would be applied to "this regulation is necessary" for example. I and many others would then have a "thort"

Re: More RCVS red tape

Anthony Todd — Tue, 15 Jun 2010 00:15:00 GMT

[quote user="Lizzie Lockett"]The Provision of Services Regulations state that service providers must make certain information available to their clients - including "the geographic address at which the provider is established". See Part two, duties of service providers, paragraphs 7-8.[/quote]

Can't find anything about "confirming annually" or ticking boxes???

Actually, registering once, with a current contact address, including email, is fair logical and reasonable IMHO. If these change then, I suspect, the most bone headed, feckless vets of no fixed abode, even locums, ;-), will update their details.

It's the add-ons,which seem to be just that, that annoy me.

And don't start me on the VMD........

Does no one in authority ever apply common sense??

Re: More RCVS red tape

J G Wray — Mon, 14 Jun 2010 22:29:17 GMT

Dear Ms Lockett,

Your point about Ms Hern is well made, but she is, as you say, not practising and the whole premise of this discussion relates to those who do. You chose to use the analogy of the Law Society's requirements for practising solicitors having a working address on their Register, not me and that analogy is false. You should not have made that point falsely, because it undermines the veracity of the rest of your statement. Checking facts and all that. All that is required of a solicitor to have a practising certificate is a fee, self-certification of CPD and proof of an indemnity policy, all renewed annually. The Roll info is static, unless the solicitor wishes to change it.

You have also made the point that it is a requirement for service providers to let the public know where they discharge that service. We are the service providers, not RCVS and we let the public know where we work. We always have. Who doesn't if they want to make a living? Since when has the RCVS touted for us?

[quote user="Lizzie Lockett"]Exemptions
The draft Registration Regulations state that exemptions to the work address requirement can be made at the Registrar's discretion. In practice, protocols will be established for groups of individuals that may seek this alternative - for example, recent graduates, locums etc - so that the Registrar will not have to agree to each individually. This will avoid the huge increase in workload (and cost) that you anticipate. [/quote]

Ah, now that's not what Ms Fraser in Registration told me on the phone. She made the point that the Registrar would be doing this. However, if there are protocols and someone is refused, the idea of being dropped from the Register because some other, more basic functionary can't make the vet's address application fit a template impresses me even less.

The explanations you have given here do not appear in the initial Press release. Why not?

JGW

Re: More RCVS red tape

Vikki Halliday LLB — Mon, 14 Jun 2010 22:19:07 GMT

[quote user="Evelyn Barbour-Hill"]Jeepers, Vikki. You deserve an award for devotion to duty.[/quote]

Well you know Evelyn, I'm a service provider so I aim to please............

Re: More RCVS red tape

Evelyn Barbour-Hill — Mon, 14 Jun 2010 21:12:21 GMT

[quote user="Lizzie Lockett"]U regulations
The Provision of Services Regulations state that service providers must make certain information available to their clients - including "the geographic address at which the provider is established". See Part two, duties of service providers, paragraphs 7-8.[/quote]

Who is to say that a "service provider" (hideous term) is each individual veterinary surgeon - rather than a practice, as any rational ordinary person would suppose?

Incidentally, why in this country do we rush to "implement" (with knobs on) every "Directive" that comes from the un-elected, anonymous Brussels bureaucrats? Why do we not take a more European attitude; that is to say, ignore it for as long as possible and then do the very minimum necessary?

Re: More RCVS red tape

Evelyn Barbour-Hill — Mon, 14 Jun 2010 21:04:10 GMT

Jeepers, Vikki. You deserve an award for devotion to duty.

So, there we have it. There is absolutely no requirement for the RCVS to register a veterinary surgeon's work address.

But Belgravia House thought they would demand it anyway, just to be helpful. Hmm.

I suggest that we all go on registering under whatever address we please.

Re: More RCVS red tape

Vikki Halliday LLB — Mon, 14 Jun 2010 16:27:59 GMT

7.—(1) The provider of a service must make available contact details to which all recipients of the service can send a complaint or a request for information about the service. (2) Those contact details must include in particular— (a) a postal address, fax number or e-mail address, . (b) a telephone number, and . (c) where the service provider has an official address, that address. . (3) In paragraph (2)(c) “official address” means an address which a person is required by law to register, notify or maintain for the purpose of receiving notices or other communications. Other information to be made available 8.—(1) The provider of a service must make the following information available to a recipient of the service— (a) the provider’s name; . (b) the provider’s legal status and form; . (c) the geographic address at which the provider is established and details by which the provider may be contacted rapidly and communicated with directly (including, where the provider may be contacted and communicated with by electronic means, the details of how the provider may be so contacted and communicated with); . (d) where the provider is registered in a trade or other similar public register, the name of the register and the provider’s registration number or equivalent means of identification in that register; . (e) where the activity is subject to an authorisation scheme in the United Kingdom, the particulars of the relevant competent authority or the electronic assistance facility referred to in regulation 38; . (f) where the activity is subject in another EEA state to a scheme equivalent to an authorisation scheme, the particulars of the authority involved or the single point of contact in that state; . (g) where the provider exercises an activity which is subject to VAT, the identification number referred to in Article 22(1) of the Sixth Council Directive 77/388/EEC of 17 May 1977 on the harmonisation of the laws of the member states relating to turnover taxes – Common system of value added tax: uniform basis of assessment(13); . (h) where the provider is carrying on a regulated profession, any professional body or similar institution with which the provider is registered, the professional title and the EEA state in which that title has been granted; . (i) the general terms and conditions, if any, used by the provider; . (j) the existence of contractual terms, if any, used by the provider concerning the competent courts or the law applicable to the contract; . (k) the existence of any after-sales guarantee not imposed by law; . (l) the price of the service, where a price is pre-determined by the provider for a given type of service; . (m) the main features of the service, if not already apparent from the context; . (n) where the provider is subject to a requirement to hold any professional liability insurance or guarantee, information about the insurance or guarantee and in particular— . (i) the contact details of the insurer or guarantor, and . (ii) the territorial coverage of the insurance or guarantee. . (2) For the purposes of paragraph (1), information is made available to the recipient if— (a) it is supplied by the provider to the recipient on the provider’s own initiative, . (b) it is easily accessible to the recipient at the place where the service is provided or the contract for the service is concluded, . (c) it is easily accessible to the recipient electronically by means of an address supplied by the provider, or . (d) it appears in any information document supplied to the recipient by the provider in which the provider gives a detailed description of the service.

So basically the RCVS wants to act as an information database for everything including which Insurance firm you take out liability insurance with, what your business address is and what your charges are. However the draft regulations do not anywhere that I could find make it an obligation of the Regulatory Body, (the RCVS) to hold or publish this information, so long as the individual complies and gives this information to the client at the time of registration. Which we mostly do already. Another hoop to jump, for no good reason.

Re: More RCVS red tape

Lizzie Lockett — Mon, 14 Jun 2010 15:07:14 GMT

Dear Mr Wray

With reference to your points in this post and others:

Law Society
Miss Hern does not hold an annual practising certificate but remains on the Roll of Solicitors - effectively in the equivalent of our 'non-practising' category - which requires an annual declaration, including confirmation of contact details, as well as the payment of a fee.

EU regulations
The Provision of Services Regulations state that service providers must make certain information available to their clients - including "the geographic address at which the provider is established". See Part two, duties of service providers, paragraphs 7-8.

http://www.opsi.gov.uk/si/si2009/draft/ukdsi_9780111486276_en_1

The RCVS Council was trying to make it easier for veterinary surgeons to comply with this new regulation by asking for work addresses for the Register, so that the public can be pointed to the Register if they make an enquiry. NB another address can be registered with us for mailing purposes.

Exemptions
The draft Registration Regulations state that exemptions to the work address requirement can be made at the Registrar's discretion. In practice, protocols will be established for groups of individuals that may seek this alternative - for example, recent graduates, locums etc - so that the Registrar will not have to agree to each individually. This will avoid the huge increase in workload (and cost) that you anticipate.

Yours sincerely

Lizzie Lockett

Re: More RCVS red tape

Arlo Guthrie — Mon, 14 Jun 2010 14:56:16 GMT

And lastly,, I've written a news piece about this:

http://www.vetsurgeon.org/blogs/veterinary_news/archive/2010/06/14/18682.aspx

Re: More RCVS red tape

Arlo Guthrie — Mon, 14 Jun 2010 14:53:09 GMT

[quote user="Anthony Todd"] Please, Lizzie, explain the need then the logic then regulate, if necessary, later.

You'll find you've done it the other way round. [/quote]

Should perhaps highlight that Lizzie isn't the regulator, merely the messenger, who - by the way - you shouldn't shoot!

I say 'merely' - she and her team do an amazingly good job of communicating (and listening, Evelyn) under what must often be, er, challenging circumstances.

Re: More RCVS red tape

Arlo Guthrie — Mon, 14 Jun 2010 10:53:52 GMT

[quote user="Anthony Todd"]There is obviously an enormous need for a "Vetsurgeon dot org" candidate or two for election to the RCVS. Simple for "our" candidate to canvass opinion from the 4000 plus [are they all MRCVSs?] also get ideas from all of us.[/quote]

I love this idea - and if there is further support for it, I would do everything to help.

No, not all members are MRCVSs - we have industry members and overseas members. But the great majority are MRCVSs, and the number is growing all the time.

Re: More RCVS red tape

Evelyn Barbour-Hill — Sun, 13 Jun 2010 20:12:50 GMT

[quote user="Richard Stephenson"] I'm afraid it is our European friends to blame for that aspect of the new regulations. The EU Professional Services Directive requires that we register the main place of work rather than a home address so i guess we have no choice but to enforce that particular rule. [/quote]

I would be glad if somebody from Belgravia House could point out precisely where this "Directive" explicitly says that the RCVS must register a veterinary surgeon under his or her work address. Because I'm blowed if I can find it.

(Of course, since I'm so disorganised, blind, ineffectual and generally lacking in turgid-selfserving-bureaucracy-generated-document-scanning skills, I obviously deserve to be removed from the register anyway).

Re: More RCVS red tape

jamie winstone — Sun, 13 Jun 2010 19:46:32 GMT

It is issues like this that I feel the BVA should stand up for their individual members. The idea of being struck off for failing to tick a box is totally against natural justice.

Although it could be argued that this individual piece of red tape is pretty minor, it is another one and the amount of paperwork and regulations seems to be relentless.

Please BVA start protesting or you may find someone organises a union............

Re: More RCVS red tape

J G Wray — Sun, 13 Jun 2010 17:35:48 GMT

If anyone can be bothered the Euro Directive can be found at

and the document downloaded from there. It's the third or fourth down file51666.doc

I can't see any specific requirement for business addresses.

Ah well.

JGW

Re: More RCVS red tape

Richard Stephenson — Sun, 13 Jun 2010 17:00:33 GMT

[quote user="Evelyn Barbour-Hill"]Sorry to hassle you Richard, as I know you opposed the proposal anyway, but you (so far) are the only Council member with the courtesy to offer an explanation on this forum. Why on earth does it have to be your WORK address? All Belgravia House needs is AN address..... unless they wish to snoop of course (perish the thort).[/quote]

Dear Evelyn,

There is a answer to that. I'm afraid it is our European friends to blame for that aspect of the new regulations. The EU Professional Services Directive requires that we register the main place of work rather than a home address so i guess we have no choice but to enforce that particular rule. In fact a member of my family lists himself under his home address for exactly the reason you give above so I know where you are coming from.

I don't particularly object to this part of the regulation especially since exemptions can be granted for members who (for example) work in research institutions. But the real question should how does this enable us to regulate more effectively. To that I struggle to find an answer.

I'm sorry that none of the members of council actually in favour of all this have offered any explanation on this forum - I felt I should at least EXPLAIN the decision - as I didn't think it fair to let Lizzie Lockett face the wrath of the members without any support!!

Richard Stephenson.

P.S. I agree with you that some of the comments made by those in favour have served to alienate rather than build consensus - that how I feel anyway.

Re: More RCVS red tape

Evelyn Barbour-Hill — Sun, 13 Jun 2010 16:32:31 GMT

[quote user="Richard Stephenson"]The plan is to supply a SAE with your renewal notice so if you haven't changed your WORK address then you will simply tick a box and send it back.[/quote]

Sorry to hassle you Richard, as I know you opposed the proposal anyway, but you (so far) are the only Council member with the courtesy to offer an explanation on this forum. Why on earth does it have to be your WORK address? All Belgravia House needs is AN address..... unless they wish to snoop of course (perish the thort).

Many veterinary surgeons like their work address to be their registered one. Others would much prefer their RCVS correspondence to be sent to their house, or maybe their family (parental) home. As long as it's a genuine address, it doesn't matter if it's just an accommodation address: it's up to the member to pick up their mail from time to time. Where, or at what, a member of the RCVS is working is no business of Belgravia House.

[quote user="Richard Stephenson"]Never the less I hope the above will dispel some of the quite understanable anxiety that the comments by two members of Council (reported in the Vet Rec yesterday and discussed in this forum) have no doubt caused.[/quote]

The anxiety really is occasioned by the thought that two members of the Council of our Royal College should be so, ummmm........... shall we say bone-headed, and so contemptuous of those who actually practise in this profession, that they make these comments in an open meeting well knowing that their words could be widely reported.

Re: More RCVS red tape

Anthony Todd — Sun, 13 Jun 2010 00:40:38 GMT

[quote user="Anthony Todd"]Under what circumstances, exactly, would the confirmation of current address be vital, bearing in mind that this confirmation could be one year out of date.[/quote]

Still waiting for just one example, hypothetical will do.

There is obviously an enormous need for a "Vetsurgeon dot org" candidate or two for election to the RCVS. Simple for "our" candidate to canvass opinion from the 4000 plus [are they all MRCVSs?] also get ideas from all of us.

Re: More RCVS red tape

Richard Stephenson — Sun, 13 Jun 2010 00:03:15 GMT

Dear Rebecca,

As I've already said I'm opposed to these new regulations but I think I can set your mind at rest on your particular concerns.

1) The new regs won't come into force until they are approved by the Privy Council - so they certainly don't apply this year.

2) The plan is to supply a SAE with your renewal notice so if you haven't changed your WORK address then you will simply tick a box and send it back.

3) Eventually you will be able to do this online.

4) If something goes wrong and your reply is 'lost' then you will get several reminders before your name is 'removed'. A time frame of at least 6 months is allocated to this process.

To Clive's point about 'no fixed abode' - remember it will be your main place of work that should be registered and only if you have no place of work your home. If you have no fixed address for either then you will need to contact the registrar who has the power to accept a different arrangement. Currently we have 150 members who are using the RCVS itself as a holding address for example.

in my view this is all over the top regulation and doesn't address the main concern of the PUBLIC which is people who are not entitled to be registered (like R Oakes) getting on the Register (although the College has taken active steps to try to prevent that from happening again).

Never the less I hope the above will dispel some of the quite understanable anxiety that the comments by two members of Council (reported in the Vet Rec yesterday and discussed in this forum) have no doubt caused.

Yours,

Richard Stephenson.