If you took a poll you would find few who think the GCC are doing a good job,the four Chiropractic associations, the Chiropractic Patient Association, the GCC have no evidence that patients who made complaints were satisfied with their job. I would guess the confidence in the GCC is now less than when the Bankside law survey showed 77% of chiropractors had no confidence in the GCC.Especially when they hear a Physiotherapist is chair of the education committee.
Nevertheless every year the GCC manage to get the CHRE (another Quango with little purpose) to write excellent reports about the GCCs regulatory activities. This CHRE report is probably the best yet and in many instances is very specific, for example, I get a mention “We also commend the strong leadership that was displayed in promptly removing from Council a member who had committed a serious breach of governance”. This also makes it easy to pull it apart.
The General Chiropractic Council (GCC) is an efficient and effective regulator. It has well planned and thought out strategies. It takes its role seriously and aspires to, and often attains, excellence. It helps to improve regulation generally by taking an active role and making a constructive contribution to cross-regulatory projects and through its engagement with European and international regulation.
The GCC provided an open and transparent self-assessment response, particularly in relation to its handling of a number of complaints/concerns about its Investigating Committee and Council. We appreciated this as it enabled us to gain a thorough understanding of the issues. The GCC provided evidence that all the issues raised in the complaints to CHRE had been dealt with appropriately by the GCC at the time the matters occurred.
The GCC demonstrates excellence in the following areas:
• the level of stakeholder involvement achieved in its work to revise the Code of Practice and Standards of Proficiency
• the achievement of parity of public and professional membership on its Communication Strategy Working Group
• requirement for all potential registrants and registrants renewing their registration to sign a personal declaration that they will comply with the GCC’s Code of Practice and Standards of Proficiency
• collection of attributable ethnicity and disability data
• reviewing the effectiveness of its work to raise public awareness of the need to check that a chiropractor is registered with the GCC
• the inclusion in the complaints information pack of the layout of the room in which hearings take place to try to allay the anxieties of witnesses to fitness to practise cases
• active involvement in cross-regulatory projects and development of European and international regulation
• swift and effective resolution of a serious breach of governance.
We will consider progress on:
• the new development and appraisal system for fitness to practise committee members
• further success on the collection of attributable ethnicity and disability data
• the outcome of the external analysis of the Investigating Committee and Professional Conduct Committee’s reasoning for their decisions.
The GCC revised its Code of Practice and Standard of Proficiency in 2008. As part of this, it held stakeholder workshops for registrants, chiropractic students and members of the public/patients. It also received written submissions from stakeholders, including the chiropractic professional and patient associations. We commend the GCC for the level of stakeholder involvement it achieved. We are also pleased that the feedback received indicated that the documents were patient focused, used clear language, and were comprehensive and well-structured.
The GCC has a well developed communication strategy for informing the public about the standards chiropractors should meet. There is a constantly increasing demand for its leaflet What can I expect when I see a Chiropractor, and the GCC continues to encourage libraries and Citizens Advice Bureaux to stock this publication. The GCC has also made efforts to improve its communications by recruiting four members of the public to its Communication Strategy Working Group. They have already contributed to the GCC’s work. The members are drawn from a range of backgrounds and interests. We are encouraged by this development, particularly as health regulators tend to find it difficult to secure active participation from members of the public.
The GCC has an efficient registration process and has 100% compliance with its service standards for registration. From 2009, all potential registrants and those registrants renewing their registration must sign a declaration that they have read the GCC’s Code of Practice and Standard of Proficiency and understand that their actions will be judged against these standards and principles. We are pleased to note this development by the GCC. We consider that it confirms the importance of these documents to a chiropractor right at the start of their career.
The GCC’s on-line register has been improved so that it is clearer to enquirers. When checking an individual professional’s entry, where there is a sanction, enquirers can click on a direct link to the summary of a case and the full decision. When checking the GCC’s register we found three cases where the sanction imposed on the registrant was not correctly reflected on the register or was not reflected at all. The GCC informed us that this was due to an administrative error which was corrected immediately. The GCC has since built in an additional check to the process to prevent a recurrence. In order to protect the public, the register should be complete and accurate. We commend the speed at which this issue was rectified and the remedial action taken.
Last year, in order to raise public awareness of the need to check that a chiropractor is registered, the GCC used a banner advert on the relevant pages of yell.com. The GCC identified that usage of this facility decreased over time and that 60 per cent of visits to its website were through referrals from Google. The GCC has now moved to a sponsored Google link and will monitor usage of this to ensure that it remains an effective method of communication. We consider this commitment to continuous improvement around a key patient safety issue to be excellent.
The GCC has demonstrated excellence in collecting attributable ethnicity and disability data in relation to 71 per cent of its registrants. Even so, the GCC wants to improve on this and is looking at different ways of doing this. We will follow this up with the GCC in next year’s review.
Fitness to practise
The GCC provides the public with thorough information about its role and its fitness to practise processes. We note that the GCC also suggests alternative sources of advice and support for complainants. The GCC has improved this information by including in the complaints information pack the layout of the room in which hearings take place. This was in response to feedback from witnesses who had been anxious about not knowing the layout of the room in advance. We support the GCC’s responsiveness to this matter.
Most chiropractors are self-employed, though some newly qualified chiropractors are employed by other chiropractors for at least the first year of their career. The GCC is undertaking a survey on this issue to establish whether further engagement with employers on regulatory issues such as fitness to practise is necessary. Again, we support the GCC’s responsiveness to this matter.
The GCC identifies serious cases quickly and, where necessary, refers them for consideration of an interim suspension order. We support the GCC’s continuing attempt, which requires changes to its legislation, to increase from two to six months the maximum time period for which interim suspension orders at the investigating stage can be applied. We have identified this as a priority in our advice to the Department of Health.
The GCC has cleared the backlog of complaints which it had received over several previous years. We were pleased to note that in light of the suggestion made in last year’s performance review, the GCC revised its service standards and we now consider that they are appropriately challenging and ambitious.
Due to the GCC’s prompt response to regulatory reform, the GCC has achieved separation of its Council and Fitness to Practise Committee functions. All members of its Fitness to Practise Committees are now appointed against clear and appropriate competencies. We are impressed at the efficiency of the GCC on this matter. The GCC is currently gathering good practice from the other regulators to enable it to develop a new appraisal system for its Committee members. We encourage cross-regulatory learning on this issue and will be considering whether we can add value to the debate.
The GCC has a mechanism to audit internally the workings of its Investigating Committee to ensure that it has followed the correct process. It has commissioned an analysis of the Investigating Committee’s decisions and those of its Professional Conduct Committee. We will be interested to see the outcome of this audit.
The learning outcomes of education programmes are derived from the Code of Practice and Standards of Proficiency. As these have recently been revised, the GCC plans to review the criteria for recognition of education providers to ensure that they are up to date and remain focused on patient safety. We welcome the GCC’s plans to ensure stakeholder involvement in this review.
Although the GCC does not register chiropractic students, it has, like some other regulators, required its education providers to have student fitness to practise committees. These committees can impose sanctions including the removal of students from the education programme. We support such mechanisms which enhance patient safety and instil a sense of professionalism in students at an early stage in their studies. Unlike other regulators, the GCC requires education providers to notify it of the outcomes of student fitness to practise hearings, so that the GCC is aware of an applicant’s fitness to practise history.
In response to last year’s performance review, the GCC has improved the input patients can have in its quality assurance of education providers. From September 2008, visitor panels will hold a separate meeting with patients to enable them to feed back their views.
Governance and external relations
We commend the speed and efficiency of the GCC in implementing regulatory reform. The GCC has a new Council which has equal representation of public and professional members and whose members were independently appointed against set criteria. Additionally, the GCC’s Council meeting papers are now available online as well as agendas and minutes.
We also commend the strong leadership that was displayed in promptly removing from Council a member who had committed a serious breach of governance
We are pleased that the GCC took the earliest opportunity to review its risk register against our ‘Special Report on the NMC’ last year to identify any lessons that should be learned. We consider it imperative that there is cross-regulatory learning both in terms of good practice and areas for improvement.
The GCC has a clear and accessible ‘complaints about us’ process and seeks to learn from the complaints it receives.
We have received some complaints about the GCC this year. We welcome the open and transparent responses from the GCC that we received in relation to these complaints and in the performance review. We are assured that the GCC has appropriate governance and fitness to practise processes in place.
The GCC demonstrates excellence in its engagement with national, European and international regulatory activities, particularly given the size of the organisation. It is clear that it actively participates in such work because of the important common interest of public protection which all parties share.