Faced with a significant drop in income, the Health and Care Professions Council proposes to raise its registration renewal fee by almost 18 per cent. Sally Gosling sets out the CSP’s objections
The CSP is very conscious of member concerns about the proposal from the Health and Care Professions Council (HCPC) to increase its registration fees.
As the society prepares its response to the HCPC's consultation, it wants members to share how they feel about the proposals and the areas of concern set out in this article.
Members can take part in a CSP webinar on the fee consultation on Tuesday 27 November at 5pm.
Event password: CSP271118.
Of course it’s also important to put the HCPC proposals into context. As well as responding to the consultation, the society is pursuing the root cause of the fee increase: the government’s decision, made in 2016, to set up a new regulator for social workers, Social Work England, in 2019.
The HCPC has indicated that its income is due to fall by £9m per year as a result, while its costs will only fall by £3m.
Unlike most other healthcare professions, social workers are separately regulated in each UK country. Social workers in England are currently the biggest professional group regulated by the HCPC, with nearly 98,000 registrants. Physiotherapists are the second biggest group, at nearly 55,000. The HCPC is therefore needing to address a significant fall in income.
A proposed 18 per cent fee increase
The central proposal is to increase the current registration renewal fee from £90 to £106 per year, an increase of 17.8 per cent.
As an independent body, without regular government funding, the HCPC relies on the income it generates to enact its regulatory functions. It is proposing to address its projected annual £6m deficit in several ways:
- Increase the annual renewal fee charged to registrants from September 2019; if progressed, CSP members would pay the increased registration fee from early 2020, when physiotherapy registrants are next due to go through the registration renewal process
- Increase other fees charged to individuals relating to their registration status (eg, overseas-qualified practitioners applying for registration, individuals returning to the register after a career break and individuals seeking reinstatement after being removed from the register)
- Remove the current 50 per cent reduction in the registration fee for the first two years of new graduates’ registration
- Explore charging new fees for activity to which no cost is currently attached (eg, the HCPC’s education approval role)
- Streamline HCPC processes to increase efficiencies and reduce costs.
The society is concerned about the proposed fee increases. Primarily, it would be a significant single increase for members as individual registrants, when payment of the renewal fee is essential to practise as a physiotherapist in the UK.
Other CSP concerns include:
- The removal of a reduced registration fee for new graduates seems badly timed when new physiotherapy (and other healthcare) graduates will start to pay back higher student loans in England from 2021; this follows the removal of the NHS bursary system in England for undergraduate students in 2017 and postgraduate pre- registration students in 2018
- While the HCPC needs to achieve efficiencies, it has to uphold confidence in its public protection role and stakeholder engagement. It also needs to address shortcomings identified by the Professional Standards Authority in its handling of fitness-to-practise cases
- The HCPC has invested in its buildings in line with its current business; while decisions to expand are understood to have been made before the government announced changes to social work regulation, increases to registrant fees cannot be used to mitigate loss of income arising from this
- The HCPC’s specific, initial indications on possible models for charging education providers for enacting its education approval role could challenge providers’ engagement in the CSP’s own education accreditation process; this could put education quality and innovation at risk.
Some positive proposals
The CSP plans to indicate the merits of some of the consultation proposals. These include the plan to keep the registrant fee under regular review in line with inflation and to avoid the need for significant, occasional increases being proposed in the future. Its intention to ensure it aligns with the full implications of devolution and enhance how it captures and shares data are also welcome.
How fees compare
The proposed increase to the HCPC registration fee needs to be put into context. With the increase, the HCPC would still charge the lowest annual fee among UK statutory regulators. The next lowest fee – £120 – is charged by the Nursing and Midwifery Council, while the highest fees are charged by the General Dental Council and General Chiropractic Council, at £890 and £800 respectively. The current average across all UK regulators is £428.
The renewal fee is tax deductible for standard rate UK taxpayers. This means that the proposed HCPC fee would reduce by 20 per cent to £85.
How you can get involved
The CSP is preparing its response to the consultation, to be signed off by CSP council and submitted by the 14 December deadline. Member feedback will be used to inform the CSP response.
Share your views
- CSP members are encouraged to continue to share their views on the consultation. One way is to take part in a CSP webinar on the fee consultation on Tuesday 27 November at 5pm. (Use event password: CSP271118)
- Members are also strongly encouraged to respond to the consultation directly. This can be done through the HCPC’s online consultation process.
- The CSP is contributing to the response of the Allied Health Professions Federation (AHPF)
- Alex MacKenzie, chair of CSP Council, is meeting with the interim HCPC chair and the HCPC chief executive this week (November 21) to discuss the society’s concerns
- The CSP is contributing directly to the review of the HCPC’s education approvals process, due to get under way in December 2018 (a public consultation on proposed changes to the regulator’s approach is due to be held in 2019).
- A public consultation on whether and how healthcare regulation should be updated closed early this year and the outcome is yet to be reported. The CSP’s response to this consultation.
Author: Dr. Sally Gosling, Assistant Director, CSP Practice & Development
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