Part 5: Modernising RCVS registration

Recommendation 5.1: Introduce provisions to allow limited licensure in principle, including for those with a disability

56. In the context of the veterinary profession, ‘limited licensure’ refers to the concept whereby a suitably-qualified individual would be licensed to undertake less than the full range of activities that could be considered to be acts of veterinary surgery, or work that would otherwise require someone to be registered as a veterinary surgeon. In principle such limitations could range from being restricted from undertaking a specified act or area of practice, through to only being licensed to undertake a specific procedure or area of employment.

57. There is no provision for UK-qualified veterinary surgeons to operate under limited licensure. The general license for veterinary surgery is considered an international standard (particularly for the purposes of certification, for instance in international trade of animal and animal products) therefore at the present time there is limited appetite for a general introduction of limited licensure for domestic graduates, but this may change in future. Further, in future there may be an appetite for RCVS Council, after due consultation, to introduce limited licensure for overseas veterinary graduates whose degree does not qualify them for a general UK licence. This could allow the RCVS to help to address workforce shortages without undermining the assurance of standards.

58. The LWP considered whether limited licensure should be permitted for UK graduates where disability prevents them from being able to undertake all aspects of a veterinary degree and veterinary practice. For instance, an individual may not be able work in practice due to a disability, yet still be able to teach, undertake research, work in pathology, veterinary regulation, politics or policy. Limited licensure could permit such candidates to complete the relevant education for a branch of veterinary surgery, and allow them to become Members of the College. The RCVS Diversity and Inclusion Working Group will be exploring detailed proposals in due course, but it would require amendments to legislation to implement any such reforms.

Recommendation 5.2: Empower the RCVS to introduce revalidation

59. The First Rate Regulator report noted that “Most regulators already have a role in ensuring that, once registered, registrants remain up-to-date with evolving practices and continue to develop as professionals”.^[11] In 2007, a Department of Health report^[12] proposed that all the statutorily-regulated health professions should have arrangements in place for ‘revalidation’, to ensure that health professionals remain up to date and demonstrate that they continue to meet the requirements of their professional regulator as they are now, rather than when they first registered. The professional standard against which each is judged is the contemporary standard required to be on the Register, and not the standard at the point at which the individual may have first registered.’

60. The GMC became the first UK health regulator to implement a system of revalidation; the five-year revalidation cycle takes into account a local evaluation of a doctor’s practice through annual appraisal. The appraisal is carried out by an experienced independent doctor, and then referred to a ‘responsible officer’ who has a statutory responsibility for making a revalidation recommendation to the GMC. The responsible officer makes a recommendation about the doctor’s fitness to practise to the GMC based on the outcome of the doctor’s annual appraisals over the course of the five years, a portfolio of supporting information that meets the GMC requirements, and whether there are any outstanding concerns for any part of the doctor’s scope of work.  Following the responsible officer’s recommendation, the GMC decides whether to renew the doctor’s licence to practise. Revalidation aims to give assurance that individual doctors are not just qualified, but safe. It also aims to help identify concerns about a doctor’s practice at an earlier stage and to raise the quality of care for patients by making sure all licensed doctors engage in continuing professional development and reflective practice.

61. Under the VSA, providing that conditions of registration are satisfied, a person may continue to be registered for the whole of their life (providing they pay their fees and are not removed by DC or for lack of response); there is no requirement to revalidate as there is with other professions. The LWP recommends that the RCVS be empowered to introduce a system of revalidation in future, should RCVS Council decide to do so.

Recommendation 5.3: Underpin mandatory continuing professional development (CPD)

62. The First Rate Regulator report noted that “CPD is a requirement for all professionals wishing to register with the health professional and legal services regulators.”^[13] However, the VSA does not give the RCVS the power to enforce this requirement, except through the disciplinary process. MsRCVS are asked to certify that they have satisfied the CPD requirement as part of the annual renewal process. However, if they do not there is no power to refuse renewal of registration. The LWP recommends that the RCVS should be empowered to refuse renewal of registration if a veterinary surgeon fails to meet their minimum CPD requirement.

^[11] First Rate Regulator report 2013, P25
^[12] Trust, Assurance and Safety – The Regulation of Health Professionals in the 21st Century (Communications Department of Health 2007a)
^[13] First Rate Regulator report 2013, P30