Abstract
HCPC Registration for Sonographers
Much has been written over the last few months regarding the issue of sonographer registration with the HCPC (Ultrasound 2014;
I am a New Zealand-trained radiographer and sonographer with a DMU and NDMDI. I have not practised radiography for 15 years and have been a specialist musculoskeletal sonographer for 11 years. When I applied for HCPC registration, I provided a transcript of study from my radiography course as well as references pertaining to my radiography career. I also supplied references and evidence of CPD in my ultrasonography practice and subsequent specialisation into MSK, as well as diplomas and anything else they required as evidence of good practice. My New Zealand Radiography National Diploma is recognised in the UK, and I have many New Zealand radiography colleagues who have HCPC registration.
After months of being required to supply extra documents, references and proof of my professional standards, the HCPC wrote and stated, the evidence provided for the possession of skills and relevant experience in sonography appear entirely satisfactory, but to be registered as a radiographer, the applicant needs to demonstrate evidence of the ability to practice safely and efficiently as a radiographer. We therefore suggest that the applicant provide a reflective piece of writing, demonstrating how the work she has been doing in the hospital environment has helped her to fulfil the current HCPC Standards of Proficiency requirements specifically as a radiographer.
How was I to complete this impossible requirement? They already knew I had been a sonographer for the last 15 years, and I had provided every shred of proof of my good radiography practice in the years before that. How many UK sonographers have to prove at registration time that they still meet the requirements to practise as a radiographer?
In my opinion, this is grossly unfair and discriminatory to overseas-trained professionals, who have a proven record of good practice. It seriously impedes career advancement in the UK, and ultimately hinders knowledge transfer and preservation of the modality. By not protecting the title of sonographer, this means that anyone can buy a machine, pick up a probe and start diagnosing without any requirement for any recognised robust training in the modality, and often without a lot of anatomical and pathological knowledge or familiarity with normal and abnormal ultrasound appearances.
Who really benefits from the current stance regarding HCPC registration? It is not the patients.
Yours sincerely
Research Musculoskeletal Sonographer
Leeds Musculoskeletal Biomedical Research Unit
Chapel Allerton Hospital
Leeds
UK
Email:
DOI: 10.1177/1742271X14565085
Editor: The HCPC was invited to give a response to Laura’s letter for publication in Ultrasound. The following is an extract from their response
Sonographers are not statutory regulated as a separate profession in the UK. This means that the title ‘sonographer’, unlike ‘radiographer’, is not protected in law, and registration is not a legal requirement to practise using this title. However, most employers will require the sonographers they employ to be appropriately registered, often with the Health and Care Professions Council (HCPC) as radiographers. Many sonographers are HCPC-registered radiographers who have then undertaken postgraduate education and training to extend their scope of practice into this area. A radiographer would need to meet all the standards set by the HCPC, which are threshold standards for the profession.
The Society and College of Radiographers maintains a voluntary register of sonographers, including a small number of practising sonographers who do not hold HCPC registration. The HCPC has previously recommended that sonographers should become statutory regulated as a separate profession. However, decisions about whether a profession should become statutory regulated and a title protected, are solely matters for the Government. The present Government has said that it will only consider statutory regulation where it can be shown that voluntary arrangements have been inadequate in protecting the public.
Letter to the Editor
The Big Issue: professional homelessness in healthcare
I sympathise very much with Laura’s situation and feel frustrated at the HCPC’s response, although it is difficult to see how else the HCPC could have acted. Its job is to ensure new registrants wishing to call themselves radiographers are able to meet minimum standards set for radiographers. Once registered, many radiographers, myself included, find themselves moving further and further away from those initial skill sets as they become specialists in ultrasound, CT or nuclear medicine. Nevertheless, they are still entitled to call themselves radiographers and, importantly, the public has some protection from poor-quality radiographers through HCPC regulation.
The fact that sonography is not a recognised profession and the title ‘sonographer’ is not protected is not the fault of the HCPC. In 2009, it recommended to government that ‘sonographer’ should be a protected title but the recommendation went unheeded, which leaves people like Laura with nowhere to register.
By denying Laura registration, the HCPC is undoubtedly putting off some UK NHS trusts and independent healthcare providers from employing her and others like her. As a consequence, our patients are having to wait longer for their examinations because staffing levels continue to fail to meet demand for ultrasound services in this country. Of course, there is no requirement for the NHS or independent companies to employ only HCPC-registered sonographers. This notion is supported by NHS Employers and the Society of Radiographers, both of whom offer invaluable comprehensive advice for employers.1,2 After all, HCPC registration is no guarantee of competence and, arguably, qualifications and a good track record are more important. I have worked at more than one NHS trust in England which have used, to excellent effect, sonographers who are ineligible for registration. Some are staff from overseas who are trained only in ultrasound. Others are midwives originally who have retrained as sonographers but whose Nursing & Midwifery Council (their HCPC equivalent) registration has lapsed, and they are no longer eligible to re-register if they have not maintained midwifery skills. Either way, they are, or have been assets to the team. It is up to healthcare providers to judge for themselves a sonographer’s ability. Why turn away sonographers with envious qualifications, exemplary employment records elsewhere and who are members of voluntary registers?
In the 21st century, and within the vast scope of imaging and oncological sciences, many radiographers have extremely specialised areas of practice now. Some of us are even starting our careers as specialists. In my opinion, if we can demonstrate all professional skills befitting our area of clinical imaging or radiotherapy, including evidence-based practice, patient care, the ALARA principle and a knowledge of national recommendations, then we should be eligible for registration as radiographers. However, in the absence of a broader definition of what constitutes a radiographer, more NHS and independent healthcare providers need to be bold and hire greater numbers of staff who are ineligible for HCPC registration.
The way forward may be for key organisations like Health Education England, Society of Radiographers, Royal College of Radiologists and Institute of Physics in Engineering & Medicine to convene urgently with the HCPC to see what can be done to start to address this issue which, incidentally, has been around for years but is simply becoming ever more pressing in over-stretched imaging departments. In March 2014, more non-obstetric ultrasound examinations were performed in England than CT, MRI, fluoroscopic and nuclear medicine examinations put together. 3
The HCPC’s raison d'être is to protect the public but I agree with Laura that its inflexibility seems out of step with rapidly evolving modes of healthcare delivery.
Department of Radiology
Lister Hospital
Stevenage
UK
Email:
References
Letter to the Editor
Part of the remit of the Health and Care Professions Council (HCPC) is to define the rules concerning who can call themselves a radiographer in the UK. In general, members of the radiography profession in this country not only accept that these rules are necessary but also that they offer a degree of protection for the public through preventing unsuitably qualified individuals from freely using our professional title. Many also recognise that the HCPC processes cannot offer total protection and that it is the responsibility of registrants, along with the public, to raise concerns about professional competence amongst fellow registrants.
It is inevitable that some highly professional and competent practitioners such as Laura will be unable to meet the threshold requirements for registration because these are based on a combination of the content of initial training and ability to demonstrate competence across the full spectrum of current entry requirements for the profession in the UK. Laura’s career progression and specialisation has resulted in her being un-registerable as a radiographer in this country, and her frustration is entirely understandable.
However, as Hazel points out, it is difficult to see how the HCPC could have taken a different view. I suspect that in the reverse situation, a DCR-qualified specialist sonographer from the UK would have similar difficulties in persuading the regulator in Australia (for example) to register as a radiographer.
There may well be work for us all to do on defining the shape of radiography and its related specialities for the future. However, that is work primarily for the professional body, not the regulator – more of this below. For the moment, I think the primary issue is about lack of recognition of the profession of sonography.
The HCPC has always supported the SCoR work to achieve protection of title and statutory regulation for sonographers. A great deal of effort went into compiling the case for this to progress, and it was on the Secretary of State’s desk at the time of the general election in 2010. The Coalition Government’s dogmatic and inflexible attitude to further regulation in health is evidenced in the Command Paper – ‘Autonomy and Accountability for Healthcare Workers, Social Workers and Social Care Workers’. 1
Since the general election, the Law Commission has completed a review entitled ‘Regulation of Health and Care Professionals’. 2 SCoR contributed to this study and specifically highlighted the inconsistencies in withholding regulation for sonographers. The report was published in April 2014. Although sonography is not specifically mentioned and the issue of unregulated groups is only one of a great many discussed, the opportunity to discuss regulation as a whole and the protection of title for sonographers, in particular, should be seized when the report is considered. The Department of Health is yet to respond and any parliamentary work on the draft bill can only now take place in the next parliament.
In the meantime, the SCoR is continuing to work with the HCPC on seeking opportunities to raise concerns about public risk that arises due to an unregulated workforce marketplace in ultrasound. We hope that there might be an opportunity to provide evidence on the subject to the Parliamentary Health Select Committee.
The recognition of acute workforce shortage in sonography is also generating considerable work and associated opportunities to raise both the regulation issue and the other points that both Laura and Hazel highlight. The need for urgent answers to workforce supply for the speciality will inevitably lead to unfamiliar and challenging solutions. None of these are simple or quick to implement. It is important that the Society of Radiographers is not only involved in these discussions but also takes a lead in ensuring that professionalism is preserved at the heart of any new models that are developed. There is obvious potential for innovations within the ultrasound workforce to prefigure changes within radiography as a whole and the professional body must be prepared to work with other stakeholders to ensure that the interests of the public, patients and professionals are understood, centralised and preserved.
Chief Executive Officer
The Society and College of Radiographers
207 Providence Square
Mill Street
London
UK
Email:
References
Letter to the Editor
Response from Laura Horton
I agree with Richard that the HCPC rules do ‘offer a degree of protection for the public through preventing unsuitably qualified individuals’ from identifying themselves as radiographers and practising as such. But what about the people who are calling themselves sonographers?
By not recognising the profession of sonographer, the UK public are at risk of, and are currently being scanned by people with either no formal ultrasound qualification, or using an unverified overseas certificate or diploma. Do the public not deserve protection from people who are in a position to provide diagnostic reports to referrers who will then treat/not treat accordingly? Do the UK and overseas sonographers who undertake a robust formal training, qualify and continue with their professional development not deserve to have their modality strengthened through recognition and accountability?
Regarding Richard’s suspicion regarding a UK sonographer registering in (say) New Zealand, a DCR-qualified specialist sonographer from the UK would not have to register as a radiographer unless they intended to practice radiography. They would register with the equivalent of HCPC in that country, the Medical Radiation Technologists Board (MRTB), in the scope of practice of sonographer. This means they are registered as a sonographer, and permitted to practice as a sonographer. The MRTB recognises the different scopes of practice and professional qualifications, ensuring that all medical radiation technologists are competent and fit to practice, regardless of their scope of practice.
The ‘professional homelessness’ that Hazel speaks of in her letter, will ultimately result in competent, innovative overseas professionals opting to stay where they are valued and able to further their careers.
Research Musculoskeletal Sonographer
Leeds Musculoskeletal Biomedical Research Unit
Chapel Allerton Hospital
Leeds
UK
Email: