Health CommitteeWritten evidence from the Royal College of Obstetricians and Gynaecologists (ETWP 44)

The Royal College of Obstetricians and Gynaecologists (RCOG) welcomes the opportunity to submit written evidence to the Health Committee’s inquiry into education, training and workforce planning, and notes that there have been some changes to the proposals in Liberating the NHS: Developing the Healthcare Workforce since it was published in March 2011. In this written evidence therefore we comment only on those issues which are new or on which we have a particular view, otherwise, our input has already been captured by our responses to Liberating the NHS: Developing the HealthCare Workforce1 and to the second phase of the Future Forum’s work.2

The RCOG understands that the Future Forum has not published interim findings and advice on education and training but will produce a full report soon. The RCOG looks forward to this report.

A Summary of the RCOG’s Views

We support the rapid development of Health Education England (HEE).

We are not in favour of the localisation of education and workforce and believe the national overview is vital.

We believe the medical workforce should be managed nationally with the engagement of the Royal Colleges.

We believe training should be controlled nationally via the HEE with the involvement of the Royal Colleges and local education providers.

The financial resources for the education budget should be controlled nationally.

Deaneries could be co-located with universities but must be independent in their governance.

1. Plans for the transition to the new system, up to April 2013

1.1 The RCOG welcomes announcement that the Strategic Health Authorities (SHAs) will continue to be accountable for postgraduate deaneries until 31 March 2013; allowing time for a phased transition of their functions. This combined with the grouping of Primary Care Trusts (PCTs) into clusters will give some measure of stability to the system during the transition. However there is clearly still much to be done and widespread uncertainty about how the new system fits together.

1.2 Based on the recently published The Operating Framework for the NHS in England 2012–13, the RCOG notes that these SHA clusters, as part of the reform programme, will work with healthcare providers and the education sector to set up provider-led partnerships on education commissioning for 2012–13 and 2013–14. It is essential that the Royal Colleges, as custodians of the postgraduate medical training programmes and curricula, are included in these discussions either individually or through the Academy of Medical Royal Colleges (AoMRC).

1.3 The Select Committee seeks views on Health Innovation and Education Clusters (HIECs). We believe their functions should transfer to Health Education England (HEE) after the transition period. Although the RCOG has not had any direct involvement with HIECs, we are supportive of their aims and would wish to see the aspiration within them develop.

2. The future of postgraduate deaneries

2.1 The RCOG has made the point in its previous submissions along with many others that the Deaneries play a pivotal role in managing the complex machinery of postgraduate medical (and dental) education. It was therefore vital to have confirmation of their future. We welcome the recent announcement that the important work of the postgraduate deaneries will continue through transition and into the new arrangements from 2013. The RCOG expects to see, in the next iteration of the proposals for education and training, clarification of the postgraduate deans’ reporting line, whether to HEE or another body. The relationship of Deans and Deaneries to the new Local Education and Training Boards (LETBs) and other relevant bodies need to be defined but the RCOG strongly supports the independence of the deans in terms of governance.

This ensures that postgraduate deans continue to oversee quality assurance in medical education and training but more importantly, are in control of planning medical recruitment according to healthcare delivery needs and nationally and locally agreed workforce plans.

3. The role of the Secretary of State for Health

3.1 As the Health and Social Care Bill makes its way through the House of Lords, the RCOG is pleased to see the amendments to ensure that the Secretary of State retains oversight of the NHS. Similarly, it must be highlighted that the Secretary of State’s duty to provide NHS services must include equal emphasis on education and training. It is therefore crucial for the Health Secretary to have a role in advancing the scope and direction of NHS education and training.

Just as the National Commissioning Board (NHSCB) is accountable to the Department of Health and Parliament, similar reporting structures must be put in place for HEE and its relationships with the Secretary of State and health ministers.

4. The proposed role, structure, governance and status of HEE

4.1 The RCOG supports the functions for HEE as set out in the March consultation document and welcomes the forthcoming proposals on the accountabilities for the quality of education and training, as there is concern of how HEE will be responsible for “promoting high quality education and training that is responsive to the changing needs of patients and local communities”.3

4.2 The roles of the GMC and the Royal Colleges in relation to the development of curricula need to be carefully borne in mind, as the latter already account to the former in this regard. Adding another layer of accountability about curricula is not appropriate. We believe that, with the proposed new reporting line of postgraduate deans, HEE will have a clearer remit for holding Deaneries to account and for working on system-wide medical issues with GMC. We noted the importance and potential of the O&G School structure for setting and maintaining standards. As these are joint deanery/college bodies, HEE will have access to national specialty advice. However, we are still uncertain about how the relationship between HEE and the NHSCB will work and more clarity is needed. There are significant risks to commissioning of services if education of the present and future workforce is not considered.

4.3 As stated in our previous consultation submission, we believe that the challenges of delivering medical education in the clinical workplace are such that the Medical Programme Board (MPB) should continue in some form as part of HEE.

4.4 With the Royal Colleges’ key role in developing education and practice standards in medicine, it is crucial for HEE to establish and maintain appropriate levels of engagement and interaction with the Royal Colleges and drive innovation and quality through the college routes. Likewise, with the introduction of Any Qualified Providers (AQP) in the NHS, HEE should actively seek the participation of the Royal Colleges in ensuring that healthcare professionals working for AQPs undergo training, assessment and qualifications.

In terms of the constitution of the HEE Board, the RCOG believes that it is crucial for the Royal Colleges to have significant representation.

5. The proposed role, structure, status, size and composition of local Provider Skills Networks (PSNs)/LETBs

5.1 The RCOG is concerned about the profusion of bodies potentially managing the provision of education locally. There are a plethora of groups below the national level, more than envisaged in March. It is not possible to recommend anything about PSNs or LETBs until there is more clarity about the respective roles and responsibilities of Clinical Commissioning Groups (CCGs), Health & Wellbeing Boards and Clinical Senates. There is a considerable risk of confusion, duplication and stagnation in the sub-national structure unless great care is taken to design the governance system as a whole. There is also the question of increasing bureaucracy with the introduction of these groups when the original intention was to reduce red tape.

5.2 LETBs are probably best accountable to HEE but this assumption may not hold for PSNs. LETBs will also probably be best based on the current national SHA and Deanery structures, and should include representation from all stakeholders involved in education and training of the healthcare workforce, plus lay and trainee membership. The role of the LETB should be to oversee the delivery of high quality healthcare education and training in its area in accordance with the priorities specified by HEE; ensure that healthcare education and training is being appropriately delivered; take local remedial action where appropriate; and to liaise with local CCGs about education commissioning priorities. How the LETBs are supported and resourced is another question for consideration. The Deanery functions and governance through commissioning would have close relationships with LETBs but be independent and perhaps relate to several LETBs within a region.

6. The role and content of the proposed National Education and Training Outcomes Framework

6.1 Overall, the RCOG welcomes the commitment to education and training demonstrated by the production of this draft Framework but suggest that much of it will be covered by local commissioning and provider relationships and quality management responsibilities. What is needed is a clear, simple set of outcomes, such as: (1) safe and excellent quality care, (2) competent and capable professionals, (3) educational outputs aligned with workforce demand. Additionally, clarity is needed on how information will be collected or analysed—through existing report mechanisms or by a new one. Outcomes need measuring and reporting through lines of accountability in this model, which will add significantly to the burden. We do not see how the seven domains match to the five outcomes or why there are a different set of domains for HEE to hold the LETBs to account (which will already have to work with a variety of educational quality standards). It is not clear how Deaneries fit into this structure, unless they are counted in the LETBs which would remove their independence and the governance.

7. The role of the Centre for Workforce Intelligence (CfWI)

7.1 The RCOG supports HEE being the responsible body for all supply issues concerning workforce and hopes that this will lead to the CfWI working more closely with the Royal Colleges. As stated in our earlier response, the establishment of HEE will provide the opportunity to plan the medical workforce centrally in conjunction with other healthcare professionals and to coordinate both workforce numbers and educational opportunities from medical school through to completion of specialist training. Against this background, we hope the CfWI will be more robustly managed and its workplan better supported. From our perspective, involvement at all stages of the CfWI work is imperative, so that models developed by the CfWI reflect the intelligence provided by our membership working within the service.

Subpoints

The RCOG hopes that the Medical Training Initiative scheme can continue in its current form. Reducing the length of attachment to just one year risks the loss of a long and respected tradition of training overseas doctors.

Compliance with the EWTR continues to challenge service provision and can impact negatively on training. For a 24/7 specialty such as O&G, flexibility is needed and the drive towards a consultant-delivered service in high risk areas of practice such as Obstetrics needs support.

Finally, the RCOG would like to reiterate the amount of good work that occurs in work undertaken by our doctors for the greater good of the NHS out with their employment contract. Provisions must be made to enable such goodwill to continue.

December 2011

1 http://www.rcog.org.uk/news/nhs-listening-exercise

2 http://www.rcog.org.uk/files/rcog-corp/RCOG%20response%20to%20the%202nd%20phase%20of%20FF_linked.pdf.

3 p.44

Prepared 22nd May 2012