REFORMING CLINICAL GOVERNANCE
This is the second in a series looking at the proposals of MSK Reform and applying them in an osteopathic context. The first article is available here.
Clinical governance is the means by which healthcare “continuously builds quality of services and safeguards high standards of care by creating an environment in which excellence in clinical care will flourish.”
There needs to be a synergy between bottom up and top down aspirations for improvement.
The reforms aim to provide assurance that:
- MSK services in the UK are continuously providing high quality care
- Every MSK clinician they encounter is safe, competent and continuously delivering high-quality care.
For osteopaths GOsC sets the standards for osteopaths to demonstrate good quality care. It is left to osteopaths to apply those standards in practice. There is some variability in quality of care provided by osteopaths.
This area is one of the passions of Mint. One of my aims with assisting osteopaths in applying clinical standards to practice was a desire to ensure that osteopathy would be known as a high-quality care profession. My concern was that whichever osteopath a patient chose to see they would receive the same high standards of consent procedures, complaints resolution, clinical hygiene, professionalism etc. no matter what emphasis the treatment would take. Consistently high standards of diagnostic and treatment reasoning is an equally important concern.
Let’s look at the Governance proposals of MSK Reform which have focussed on physios as the largest MSK profession and consider them for osteopaths:
CREATING ROBUST SYSTEMS
1. MSKR recommend that Physiotherapists be included in the CQC list of registrants required to be registered under the regulated activity of “Treatment of disease, disorders or injury”.
In the subtext MSKR also recommend that osteopaths and podiatrists are included. CQC inspections would encourage osteopaths to have robust policies and procedures in place so could be a very positive move forward. The ability of CQC to scale to inspecting hundreds of small practices is unknown.
2. MSKR advocate for the development of an accreditation process from which MSK services can aspire to a quality standard mark.
There are a lot of quality marks used in different industries. Probably one of the better known is the Investors in People award. This mark would provide a benchmark for osteopaths to attain and reassurance that you are providing good quality care.
3. MSKR propose that all providers of MSK services mandate governance training into their induction programmes and ongoing mandatory training.
In osteopathy we have mandatory requirements in our CPD which will help to maintain good governance standards. The reforms emphasise that individual clinicians should not be devoid of responsibility for implementing clinical governance. They state that clinical governance should be integral to professional, career-long learning – I think most osteopaths would whole-heartedly agree.
4. MSKR support the integration of Clinical Governance education in every level of MSK courses.
Many of the courses do include governance training but there are possibly areas of weakness such as handling complaints, continuous service improvement. I am sure there are other areas for improvement that you could identify.
CREATING ACCOUNTABLE CLINICIANS
6 & 9. MSKR propose a phasing out of the current Continuing Fitness to Practise process for Physiotherapists and HCPC registered MSK professions. MSKR propose that the revalidation process that replaces it should then involve the HCPC (or subsequent regulator) auditing 2.5% of a full profession sample against compliance standards.
There are often comments on social media about osteopaths wishing we were regulated by the HCPC so it is interesting to read of some of the dissatisfaction expressed by physiotherapists. They are concerned that HCPC has 6 standards that it failed to meet in fitness to practice in 2017/18 and 2018/19. There is an inconsistent and inappropriately high threshold for investigation of fitness to practice cases. To put this in context GOsC has fully met all the standards for the last 9 years.
They also express concern at the lack of oversight of the CPD process – 2.5% of registrants are audited. In osteopathy 20% of CPD submissions were audited on the old scheme.
7 & 8. MSKR recommend a mandatory annual appraisal as a requirement for all MSK Practitioners, which will include agreed supporting evidence aligned to HCPC (or subsequent regulator) standards. MSKR recommend that all annual appraisals should then be uploaded onto a HCPC (or subsequent regulator) database to ensure compliance assurance
This annual appraisal proposal is similar to the Peer review that osteopaths will have every 3 years. Although the peer reviews will not be submitted to GOsC by all osteopaths. Full analysis of the new CPD scheme for osteopaths will not be possible until all osteopaths have passed through the first 3 year cycle in 2022.
I found this section reassuring in terms of the high standards and reassurance we can have from the quality of GOsC regulation. It’s valuable though to consider further how continuous high standards of clinical governance could be encouraged – a quality mark, enhancing the culture at undergraduate level or CQC inspections? Plenty of food for thought and for further discussion.