Critical Thinking

In Association (BMA) and they are often independent

In a profession as ever-changing as radiography, it is important to evaluate the bodies that shape and arguably define the profession. Regulatory and professional bodies, although different, play an important role in the regulation of healthcare in the UK (General Medical council (GMC), 2017). Regulatory bodies are used in the public interest, regulating professional activity. They may have power mandated by parliament and are there to ensure professionals uphold a certain standard through having mandatory registration, providing professional standards and requiring continuing professional development (CPD) amongst other things (HEBRG, 2011; Department of Health (DH), 2015). There are twelve regulatory bodies in the UK under the Council for the regulation of Healthcare professionals (GMC, 2017). Professional bodies are different; their role is to promote and support individual healthcare professionals through being members of an organisation (Green, 2015). Examples include the British Medical Association (BMA) and they are often independent of the government. Professional bodies may also have a trade union function, representing their members interests at a government or local level as well as defending their members from regulatory bodies which will be discussed in this essay (HEBRG, 2011).

This essay will investigate how regulatory and professional bodies, particularly the Health and Care Professions Council (HCPC) and the Society of Radiographers (SoR), define the role of Radiographers by evaluating the importance and function of each respective body, assessing legislative aspects, discussing the cost and reviewing the influence they have on the radiography profession. There will also be a discussion on how they represent the profession, whether they are truly accountable and whether these bodies fulfil their roles.

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There are several regulatory bodies that influence the radiography profession. The Care and Quality commission (CQC) is described as an ‘independent regulator of health and social care in England’ who aims to ensure health care services are ‘safe, effective, compassionate and of high quality’ (CQC, 2017). Although, they are not directly linked to radiography, they are responsible for providing dose reports and acting as an independent body, put out recommendations and reports which are open to the public. Regarding radiography, the CQC is responsible for enforcing the ‘Ionising Radiation (Medical Exposure) Regulations (IR(ME)R (2017). As regulatory bodies are there to protect the public, ensuring it is appropriately enforced is key as it is there to ‘protect patients from unintended, excessive or incorrect medical exposures’. Inspectors have power from the Health and Safety Work Act (section 20) (1974) and this is often done through inspections (Skills for Care, 2017). The CQC’s most recent enforcement notice was given to the ‘Northern Devon Healthcare NHS Trust who was given an improvement notice due to concerns around the employer’s enforcement of IR(ME)R 2017 (CQC, 2017). This enforcement notice, suggests that regulatory bodies like the CQC do help to define the Radiographer’s role as they have expectations enshrined in law and actively enforce it when Radiographers do not comply.

Similarly, the Health and Safety Executive (HSE) is another independent regulatory body that is arguably responsible for the way radiography is practiced, therefore defining its role. The HSE is an independent regulator that offers advice and information regarding work related health (HSE, 2017). The HSE is responsible for enforcing the Ionising Radiation Regulations (IRR) (2017) which aims to reduce employee’s exposure to ionising radiation. The IRR (2017) also highlights that all departments should have a RPS and a RSA. In this case, the Radiographers with those respective positions do have their roles defined by regulatory bodies.

When reflecting on how regulatory bodies help define the Radiographer’s role, the Government must inevitably be included in the conversation. The government, specifically the Department of Health, has helped to create and implement legislation that shapes the way Radiographers practice their profession. The NHS reform and Healthcare Professions Act (2002) was a pivotal point in the way healthcare was implemented in the UK and came about because of the Bristol Inquiry, published in 2001 which concluded that deaths could have been avoided (Department of Health, 2015) and this has shaped the way the government has created policy.  

The HCPC is the main regulatory body to the Radiography profession. Article 39 of the Health Professions Order (2001) clarifies the protected title of a diagnostic Radiographer, making it illegal to practice unless registered with the HCPC and this is a way of defining the role of the Radiographer as they would not be able to practice without it. It was created by the Health Professions Order (2001) after the Bristol Inquiry (DH, 2015). All Radiographers must register with the HCPC, renewed every two years. It costs £180 every two years except for newly qualified professionals who pay £45 for two years (HCPC, 2017). Registration defines the role of the Radiographer as it allows us to clearly distinguish the difference between a registered professional and a student which encourages professionalism and safe practice.

‘Continuing Professional development’ (CPD) is a mandatory part of registration which should be done regularly and recorded, is defined as the way staff learn and develop throughout their career (HCPC, 2017). All healthcare professionals that register under the HCPC are expected to meet their CPD standards. To evaluate whether the HCPC truly defines the Radiographer’s role, the effectiveness of CPD must be questioned. Schostak et al (2010), questioned CPD and found that it is valued and that its quality is linked to the improvement of the service delivery of professionals. However, it was recognised that it can be viewed as a ‘tick box exercise’ and needs to be more in-depth’. This implies CPD is recognised as important but it’s quality is not always consistent. Perhaps, the only way CPD can be deemed to be effective is if it is regulated nationally meaning all trusts will do the same thing, suggesting the HCPC is disconnected from the professions it represents. It is also important to acknowledge that although it’s expected to be done constantly, staff may not comply. CPD audits are done at random at registration so there is a chance a Radiographer may end up not being audited which may result in a different quality of practice (HCPC, 2017). However, there is evidence that CPD can improve practice (Filipe et al, 2014) and the fact it remains an essential part of HCPC registration, suggests it is important.   

Although the HCPC represents several professions, it has Standards of Proficiency specifically for radiography. Published in 2003 and revised in 2007 and 2013, the Standards of Proficiency set out ‘safe and effective practice’ in the professions they regulate. It also states what students are expected to know which is reflected in the university course (HCPC, 2013). This implies that the HCPC defines the Radiographer’s role by dictating what radiography students must learn to qualify and practice. There are thirteen main points in the Standards of proficiency and number thirteen states clear differences between diagnostic and therapeutic Radiographers in terms of what they are expected to understand. Stating the standards every registered professional is expected to meet through practice and registration is important and highlights how the HCPC defines the Radiographer’s role. However, these standards were revised in 2013 so it could be said that it may not be completely relevant to the profession as it is outdated.  

Another aspect of the HCPC is to deal with complaints which can result in Radiographers being struck off the register. The most recent case of a Radiographer being struck off was in September 2017 (HCPTS, 2017). It could be said this is key in defining the role of the Radiographer as it creates an incentive for staff to not be struck off. However, it must be acknowledged that if good enough, the standards of proficiency, code of conduct and CPD that is mandatory, should make complaints avoidable and the HCPC recognises that CPD does not prove competence (HCPC, 2017). This suggests that the HCPC is not as effective as it should be. However, human error is inevitable and is expected in practice (Carayon, 2010).

Nevertheless, it is also important to recognise that the HCPC is regulated by the Professional Standards Authority (PSA) (DH, 2015). This may imply that rather than working in the best interests of staff, the HCPC works to appease the PSA and essentially the government which introduces the question of the impact politics has in the healthcare industry. Alternatively, it could be said that having the PSA increases accountability.

Professional bodies are different to regulatory bodies. The Career Transition Partnership (CTP) (2015) states that they provide people with ‘professional recognition’, a source of information and advice, opportunities for networking and support. The ‘Organisational Support Theory suggests Radiographers being valued by an organisation can yield positive benefits (Makanjee et al (2006); Kurtessis et al (2015) which implies that Professional bodies can really influence healthcare professional’s careers. The professional body for the Radiography profession is the Society and College of Radiographers, founded in 1920. They describe themselves as a ‘trade union and professional body for the diagnostic imaging and radiotherapy workforce in the UK’ who ‘shape policy and standards, pioneer new ways of working, and ensure safe and fair workplaces.’ (SoR, 2017). It represents 95% of diagnostic and therapeutic Radiographers in the UK (SoR, 2017) however, unlike the HCPC where registration is compulsory to practice, Radiographers do not have to become members of the SoR to practice which questions whether it can truly define the role of the Radiographer.

Being a member of the Society of Radiographers has benefits that the HCPC does not offer. Members are offered indemnity insurance, provided with legal representation and learning resources to name a few (SoR, 2017). Kubik-Huch et al (2010) concluded that having a good support system is important for a high quality of service and provides an incentive for staff to stay in a profession. The organisational support theory, seconds this, stating professionals who are supported in the workplace benefit from high morale and are generally happier in the workplace (Kurtessis et al, 2015). These benefits are unique to SoR members and those who are not members will not benefit from this. For membership, the Society of Radiographers charges qualified Radiographers £256 a year (SoR, 2017). In comparison, the HCPC’s registration costs £180 which is paid every two years (HCPC, 2017). Being a member of the HCPC is compulsory for a Radiographer to practice in the UK whereas being a member of the SOR, despite its benefits is not compulsory and does not prevent staff from practicing. The cost effectiveness of the SOR must be questioned, particularly when it is not compulsory but costs so much more than HCPC registration. However, the fact that over 95% of Radiographers have voluntarily chosen to join the SoR suggests that members are not deterred by its cost and recognise the benefits like educational opportunities, of being a member.

In addition, the SoR has a trade union role. Trade Unions are ‘groups of employees who join to maintain and improve their conditions of employment’ (Unison, 2017). The SoR currently have two ongoing campaigns including the NHS pay campaign, which focuses on campaigning for fairer pay in the NHS, after the government decision to ignore the recommended 1% pay rise (SoR, 2017). As part of their role as a trade union, the SoR represents their members in a legal capacity. This includes representing them at court hearings when a member has been reported. It could be argued that the HCPC and SoR work against each other in this capacity. The HCPC can prevent Radiographers from practising whereas the SoR will defend their members against this ruling. As both bodies can determine whether a Radiographer remains a Radiographer it can be said that they do define the Radiographer’s role. However, the HCPC has more power in this circumstance.

The society of Radiographers also promotes CPD and recognises it as a mandatory part of HCPC registration. This is an essential part of practice to register as a Radiographer under the HCPC guidelines (HCPC, 2017) however the SoR states that CPD can bring ‘professional and personal award’ (Coleman, 2008). This suggests that the SoR, not only recognises that CPD is a compulsory part of registration but can help staff grow and develop in their roles. Studies also show that CPD can improve practice (Filipe et al).

To support staff, the SoR runs an accreditation scheme called ‘CPD Now’, only available to members, which gives practitioners an opportunity to gain accreditation, plan, develop and evaluate their practice. Although not recent, between 2014 – 2015, 54% of the SoR membership in that year used this tool (CoR, 2017). As over 50% of members used CPD Now, it suggests this resource and overall, other tools the SoR provides are valued. As a professional body, who’s role is to support staff, the tools and resources provided by the SoR on CPD, shows they recognise the importance of CPD not just in registering but in developing as a professional. CPD gives Radiographers the opportunity to be accredited by a professional body (Coleman, 2008). However, being accredited by the SoR is not equivalent to completing the HCPC’s CPD requirements but despite this, helping to support staff with a compulsory measure for registration, can define the Radiographer’s role.

Nevertheless, it is importance to recognise the qualms against CPD. Although there are studies showing that CPD can improve practice, many have shown concerns. Research conducted by Henwood et al (2010) showed that 46% of Radiographers did not believe CPD should be compulsory and that there are financial implications and it requires staff to complete it outside of work hours. For a professional body, who’s aim is to support staff, encouraging them to undertake more can suggest it does not completely adhere to its role. Studies show that having a good work-life balance not only increases job satisfaction but contributes to a positive mental state (Haar et al, 2014).  Although it is clear CPD is perceived highly, this suggests that both the HCPC and SoR should consider adopting a different approach to CPD which is sometimes seen as a ‘tick box’ exercise (Schostak et al (2010).

In 2013, the SoR published the Professional Code of Conduct, described as ‘the most significant guidance document within radiography practice’. It sets out the expectations staff are expected to reach in practice and these are based on various values and was written with the Francis Inquiry in mind which evaluated the care at the Mid Staffordshire Trust between 2005-9. It concluded that many deaths and the poor treatment of patients could have been avoided. (Francis, 2013). This implies it focuses on the patient and as healthcare professionals, patient centred care is pivotal. It can be compared to the HCPC’s Standards of conduct, performance and ethics (HCPC, 2016) and this is recognised by the SoR that ‘accepts and builds’ on the HCPC’s code but directly applies it to the radiography profession. It could be argued that the Code of Conduct does define the role of Radiographers as it not only states the expectations of professionals and students alike, but it branches from the HCPC’s code, the body all Radiographers must be registered with to practice. However, as a professional body, the SoR has no legal foundation and as said earlier, membership is not compulsory so whilst helpful, may not always be applied to practice. Despite membership not being compulsory, there is evidence that it contributes to the development and growth of a Radiographer in their practice meaning it is incredibly beneficial.

To conclude, this essay has provided evidence that regulatory and professional bodies alike do define the role of the Radiographer but in different ways and this is expected as they have different aims and objectives. The HCPC, as a regulatory body defines the role of a Radiographer in a greater capacity as registration is essential to practice, it is supported by legislation and can prevent Radiographers from practicing. Despite this, it can be said that it is not specific enough to the radiography profession. The SoR on the other hand is a professional body created in the interests of Radiographers. It provides indemnity, legal support, CPD resources and acts a trade union working in the Radiographer’s best interests. With 95% of Radiographers being members of the SoR, it is clear that it is deemed important. However, membership is not compulsory to practice whereas registration with the HCPC is. This essay has shown evidence that both bodies are important and complement each other but regulatory bodies, particularly the HCPC is more significant in its function. 

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