Review of Public Health Regulation

 

Review of Public Health Regulation

The nature of Specialist and Director of Public Health roles are key to the current and future public health function; with high visibility and importance to tackling core challenges such as disparities in health, health protection and lifestyle burdens. Their roles, particularly related infectious disease, screening commissioning and public health budgets have substantial responsibility and potential effect on patient safety. Assurance and confidence in public health specialist practice is therefore of great importance. This review seeks to secure the confidence of both the public and professionals as to standards of competence, performance and conduct of the public health workforce through apprising the currently available options for regulation.

This review is at the evidence-gathering stage, and therefore asks questions for response. Full standard consultation will be required at the legislative stage, at which point we will carry out a full formal consultation.

Background

Public Health has always been made up of an amalgam of disciplines in the United Kingdom.  While public health medicine has been the major influence in the National Health Service Public Heath workforce over the years, public health has multi-disciplinary roots. In 1997, the Tripartite Group (Faculty of Public Health Medicine, the Royal Institute of Public Health and Hygiene, and the Multidisciplinary Public Health Forum), signed the Tripartite Agreement taking forward the development of multidisciplinary public health.

In 2001, the Report of the Chief Medical Office’s Project to Strengthen the Public Health Function made strengthening the multidisciplinary nature of the public health workforce an area for future action.  It provided for further articulating the standards for ‘specialist practice’ and for the implementation of the new Specialist post within the health service.  This has led, in the past few years, to practitioners of non-medical disciplines being able to hold high level public health posts as an occupation/profession.

In March 2003, after extensive work by the Tripartite Group and Skills for Health, the UK Voluntary Register for Public Health Specialists was established.

Medical practitioners have had a “standard route” to Public Health registration via the Faculty of Public Health, with dental public health specialists training through the programme of the Royal College of Surgeons. In terms of regulation, physicians and dental surgeons have traditionally been subject to Fitness to Practice oversight through the General Medical Council and the General Dental Council, respectively.

Non-medical public health Specialists now have entry to a voluntary register through the United Kingdom Public Health Register; medical and dental public health specialists are also accepted on to the register should they wish to apply (dual registration).  The United Kingdom Public Health Register also has a regulatory role when professional ethics have been breached or where technical competence has become an issue.

Health and Social Care Act (2008) has further changed the regulatory framework in respect of medical practitioners.  The legislation has established the framework for a new independent body to adjudicate Fitness to Practice cases referred to it by the GMC.  The Office of the Health Professions Adjudicator makes the adjudication of cases in respect of medical doctors independent from the investigation and prosecution of cases. 

Desired outcomes of the review

The review terms of reference require principles for the review to be articulated. The desired outcomes of the review are:

1. Regulation of public health will ideally include one common unified register covering medical and non-medical specialists.
2. Medical specialists will remain on the specialist register with the General Medical Council.
3. All individuals on the register will be specialist in public health (i.e. those with another speciality alone will not be eligible).
4. The chosen regulatory option will promote efficiency of back office functions, in line with Department of Health principles for Arms Length Bodies.
5. The chosen regulatory option will be self-financing following establishment.

Question for response

The Department of Health would like to receive comments as to the following proposal:
“All non-medically qualified public health ‘specialists’ currently on the UK Voluntary Register for Public Health Specialists should instead be placed on a Statutory Register. The wider Public Health workforce (i.e. those not eligible for inclusion on a Public Health Specialist register) should be subject to a self-regulation register.”

 

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