The Institute has considered at length the consultation document Modernising Scientific Careers: The Next Steps.
The Institute is the professional body that represents biomedical scientists who are the largest professional group within the healthcare scientist workforce and naturally wishes to be actively engaged in the MSC project in order to establish sufficient understanding and clarification to design a qualification framework that remains appropriate for service needs but which also provides clear, unequivocal opportunities for career progression. There is insufficient detail in key elements of this consultation document to give the Institute confidence that this will be achieved without much further discussion and accommodation.
The Next Steps document attempts to describe a vision for the establishment of a consolidated, fit for purpose, scientific workforce for a modern health service. Clearly, who could argue against such a fine ambition? However visions need to be shared from the perspective of process, and it is worrying that despite the length of this document and the scope of the project, details or even intentions about transition and implementation process are very scant. Given the significant size of this initiative it would seem unreasonable to expect those professions that have established proven education and qualification systems to abandon these for alternatives that are inadequately described in detail, process and funding. It is a generally held view that the current education and training system for biomedical scientists delivers a safe, well regulated, fit for purpose profession that meets the needs of the service The general tenor of the justification arguments used in the document imply that there is little within the current system that has merit, works effectively or indeed is safe and fit for purpose. For a number of professions within the sector, not just biomedical scientists, this is manifestly not the case, and it is difficult to see the justification for not retaining those elements of the current system that clearly work well.
Throughout the document there appear to be many assertions that are not substantiated by evidence and conclusions that are not based on fact. If the project is in effect promoting integration of professions particularly in Life Science then this is to be supported. However without any indications of the likely functionality and limitations of each grouping, which would in turn determine the relative workforce numbers and therefore funding requirements for education and training, it is difficult to envisage how this could be achieved. Indeed, with the proposals for regulation this could promote a system of segregation that would make career progression within groups limited and between groups restricted. The impression given is that movement between the different coloured boxes is possible in theoretical terms but not by a process that is inviting or practical. The Institute considers it essential that individuals are given the opportunity to achieve the outcome requirements of the STP through an equivalence mechanism whilst continuing in current employment.
It is essential for the future of patient safety and service provision that healthcare science is seen as an attractive and meaningful career. In its current format the MSC project fails to maximise the opportunity to describe an attractive career structure. The apparent segregation into three distinct groups is divisive and disappointing given the current good practice of employment philosophies. Progression can reasonably be expected to be through competition; however it is apparent in the proposals that advancement opportunities whilst in employment will be constrained by applications for funding which have yet to be addressed.
The Healthcare Scientist Practitioner grouping, presently with no identified training programme or exit qualification will not be seen as a viable prospect by many of those currently seeking employment. The way in which the graphics of the MSC are presented and the pathway described provides a vision of segregation and separation further compounded by the proposals for separate registers at practitioner and scientist level respectively. The proposed levels of registration are not supported by the Institute. It is doubtful whether it is possible to unite such a number of diverse disciplines into one group with the potential for a single set of Standards of Proficiency, without lowering public protection. A single, transparent, coherent education and training pathway based on a single threshold point for registration from which all entrants are given the opportunity to progress would give a clearer and more equitable career pathway that could recognise levels of practice whilst achieving the objective of a unified workforce. Levels of professional attainment or specialism could be recognised by annotations on the register that record areas of expertise. The project’s aim is to unite the healthcare science workforce in the interests of patient safety and service provision. The public would surely struggle to understand the implications of two separate registers within the same sector. Professional titles are inevitably linked to professional identity and the MSC proposals appear not to take into account that there are in excess of 25,000 biomedical and clinical scientists that have established protected titles that are used for good reason.
Regulation must be the key issue within this project. The Next Steps document seems to imply that the only route to regulation would be through the associated training programs. There must be alternative equivalent routes. It is meeting the standards of proficiency that is the relevant factor here, not the process by which this is achieved.
The document rightly draws attention to the large number of disparate groups within healthcare science. Nonetheless, unifying these groups has the potential for loss of identity and understanding of function by the public of some of the established groups such as audiology, medical physics and biomedical science. The Institute wishes to see the retention of the protected title ‘Biomedical Scientist’ which describes a well defined and discrete profession for the delivery and advancement of pathology services. Irrespective of future staffing structures, the knowledge and skills associated with this large group will still be required, and the Institute sees the healthcare science generic description having within it meaningful protected titles more indicative of function.
The Institute believes from the limited information available that the proposed BMedSci would be a very poor alternative to the existing accredited biomedical science degrees and would be unlikely to maintain the knowledge and skills base of the profession. This would be to the significant detriment of the service. It is a matter of fact that attrition rates amongst biomedical scientist particularly recruited from integrated degrees which deliver fit for purpose and fit for practice graduates, is very low. The Institute believes this to be an excellent example of the fashioning of a profession via the free market principles. The Institute would therefore be committed to working with the MSC team to ensure its continuation in future structures. Currently honours degree level is the minimum standard for HPC registration and the Institute wishes to see this retained.
It is recognised that MSC represents a major undertaking that will take several years to successfully implement. The MSC team has made it clear that it wishes to be inclusive and work with stakeholders to fashion the details of the project. If this is effective then inevitably there will be changes to the programme that is currently envisaged. It is imperative that during this extended period of work that appropriate recruitment to the current workforce is maintained. The Institute is concerned that documentation circulated to University Vice Chancellors about proposals for BMedSci degree programmes has already caused uncertainty and in some cases affected SHA funding support for integrated biomedical science degrees. This uncertainty and potential indecision increases the risk of adverse impact to service delivery at a critical time for the NHS. Changes made must be as far as possible seamless. The Next Steps document paints a picture of a relatively fragile and unsafe structure in some areas, if this is indeed the case a careful process of evolution would be required with ‘buy in’ from all parties.
The section of this document that deals with transition arrangements is currently inadequate. Detailed, clear and transparent principles and guidelines for transition arrangements need to be developed and the Institute would wish to be involved in this aspect of the work.
The Institute has a cohesive qualification framework supported by long established principles of education and training that produce fit for purpose biomedical scientists competent for entry into the health service workforce. This is supported by a mature CPD scheme, in-service training and further education. In addition, the Institute has an integrated framework for all levels of post registration training which it believes is responsive and adaptable to service needs and provides national standards and a currency for career progression. The Institute expects to retain ownership of its examination structure but seeks recognition of its qualifications within the context of the MSC proposals, as part of the curriculum development process.
The consultation document acknowledges that it does not seek to address funding issues. However, it is widely believed that this is insufficient to sustain the workforce that will be required to deliver the service – both now and in the future. Current funding for the education and training of many professions particularly for biomedical scientists beyond registration is dependant on ‘creative resourcing’. This funding is difficult if not impossible to identify and quantify. The Institute believes that the MSC team has not taken cognisance of the levels of funding necessary to maintain the number of staff equivalent to the present biomedical scientist workforce for example. Currently there are in excess of 2,500 individuals who are undertaking post graduate specialist training to meet the service needs of their employer locally. Insufficient or withheld funding waiting for the outcome of the MSC project would seriously destabilise the service and patient care.
It is evident that MSC would attempt to change the skill mix of the work force, but this does not necessarily relate to improvement. It is probable that individuals coming through such a system as described would do so with less skill within a specific discipline than at present. This could inhibit future service development and potentially reduce the more specialised interpretative advice that will be essential to underpin patient safety as nursing staff increase their areas of clinical responsibility. In this situation good quality scientific advice must be readily available. Consideration also has to be given to those professions in areas that provide a 24/7 service delivery. The different skill mix dictated by the greater responsibilities associated with out of normal working hours must be recognised.
Additionally there is concern that a nationally run scheme would be too inflexible particularly for the smaller professions and that adequate provision should be allowed for local variation. The document also implies support for the principles of the project from all four home countries, however there is no recognition of the very different educational systems particularly in relation to honours degree programs.
The Institute remains keen to work with the MSC team on all aspects of the project, but until far more detailed information is made available, remains committed to its core activity of ‘promoting biomedical scientists and their professional practice’.
February 2009
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