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Introduction

  1. The Royal College of Veterinary Surgeons (RCVS) is consulting on proposals to reform the composition of its governing body, RCVS Council. We would like to gather views on the potential impact that implementing the recommendations could have, and any evidence and arguments that may not have been considered. The proposals will be reviewed in light of the consultation results before a final decision is made on formal recommendations for governance reform.
  2. In June 2021, RCVS Council agreed a package of recommendations for new legislation to replace the Veterinary Surgeons Act 1966 (VSA), based on the work of the Legislation Working Party (LWP) and following extensive consultation. The VSA is the key piece of legislation that underpins the core regulatory function of the RCVS, protects the title ‘veterinary surgeon’, and restricts acts of veterinary surgery to veterinary surgeons (except where exemptions are made, such as those for veterinary nurses). The reform recommendations seek to allow the RCVS to be a modern, flexible, forward-looking regulator of the entire vet-led team, and include measures to:

    • Regulate veterinary practices
    • Regulate additional members of the vet-led team such as musculoskeletal therapists, cattle foot trimmers, and equine dental technicians
    • Create a forward-looking Fitness to Practise System
  3. When considering future reform, one outstanding question relates to the governance of the RCVS. The composition of RCVS Council – the College’s governing body - is set out in the VSA, and therefore the College needs to develop proposals for what that composition should be in any replacement legislation, including whether there should be any changes to strengthen and assure public confidence in the veterinary regulator.
  4. The VSA is the primary legislation that underpins and details the functions and governance of the RCVS, but it sits alongside the College’s Royal Charter. The Royal Charter incorporates the RCVS as an organisation, and empowers it to advance standards as well as setting and upholding them, in the interests of the health and welfare of animals and in the wider public interest. It also underpins the RCVS Fellowship and the College’s award-granting powers. This combination of Act and Royal Charter is what makes the RCVS a Royal College that regulates, allowing the College to take a more holistic approach to regulation than would otherwise be possible. However, the central role of the RCVS, underpinned by statue, is that of a regulator, and there is a strong argument that this should be reflected in its governance. It must also be clear to the public and the profession that the RCVS is not a representative body established to act in the interests of its members.
  5. A regulator is a body committed to setting and upholding professional standards in the public interest. Regulators do this by holding a register and regulating the educational standards that need to be met to join it, maintaining a disciplinary process, setting and enforcing educational standards, and enforcing regulations such as those pertaining to continuing professional development (CPD).
  6. Noting that the primary function of the RCVS is to be a regulator, at present the composition of RCVS governance is strongly at variance with the regulatory norm, and this will be highlighted as and when new legislation is considered by government, who may prefer a model closer that of other regulators. Ultimately the details of future governance reform will be in the hands of the government and Parliament, and may differ from the College’s preferred option. RCVS Council has had these arguments in mind when considering recommendations for governance reform.
  7. Unlike the RCVS, other Royal Colleges are not regulators. This does not make for an easy comparison. Other Royal Colleges are empowered to fulfil a variety of functions, such as conservatoires (Royal College of Music), trade unions (Royal College of Nurses), or professional bodies more narrowly focused on promoting educational and clinical standards (such as the Royal College of Surgeons). Most have elected governing bodies, but some do not. Some of those that do have carried out reforms to increase the number of appointed members of their governing bodies and grant them voting rights. In the veterinary sector some of the functions held by some medical Royal Colleges are carried out by our charity partner RCVS Knowledge, which has its own governance arrangements.
  8. In addition to setting and upholding standards, the College’s Royal Charter does empower the RCVS to carry out activities to advance the professions, and these workstreams are currently overseen by the College’s Advancement of the Professions Committee (APC). Following this consultation the College intends to consider proposals for continuing to reflect these functions in the composition of APC (which could include an elected component), and/or other related measures to reinforce the College’s identity as a ‘Royal College that regulates’ and the identity of veterinary surgeons and nurses (and future allied professionals) as Members and Associates.