23 Apr 2021
BVA and BVNA call for proportionate regulation in major veterinary legislation review
BVA and BVNA have responded to a major consultation from the RCVS reviewing veterinary legislation.
The leading bodies representing vets and veterinary nurses in the UK have jointly responded to a major consultation from the Royal College of Veterinary Surgeons (RCVS) reviewing veterinary legislation (closing today) with a headline call for the right level of regulation that is proportionate to the level of risk.
The British Veterinary Association (BVA) and British Veterinary Nursing Association (BVNA) response has been developed through a series of focused working groups considering the wide-ranging recommendations of the RCVS Legislation Working Party (LWP) as well as a number of interim proposals that do not require legislative change, such as changing the standard of proof for disciplinary cases. BVA and BVNA had both been represented on the LWP and had opportunities to shape its report, but our joint response brings in the views of our wider memberships.
Our overarching message in the joint response is that we support the RCVS commitment to progressing as a modern, fit-for-purpose regulator, but that there must be a holistic approach and careful consideration of the chronology of changes. The key principles of accountability and transparency must underpin any transition, and appropriate resourcing that doesn’t result in a financial burden for vets and nurses must be part of the final package.
In light of these key messages, we are recommending that the RCVS does not progress plans to change the standard of proof (from criminal to civil) in isolation. Instead, the change should only be considered after a package of measures has been implemented to foster a curative rather than punitive system.
Some of the key elements of the BVA/BVNA response (in order of the consultation paper) are:
- Support for the regulation of some groups of evidence-led allied professions via the RCVS, but with safeguards to protect the reputation of the veterinary professions (Rec 1.1)
- Support for separating employment and delegation to RVNs, but only within the context of the vet-led team (Rec 1.3)
- Strong support for the protection of the veterinary nurse title (Rec 1.4)
- A call for the development of a framework for enhancing the RVN role rather than focusing on specific tasks, such as cat castrations (Rec 2.2)
- A call for a clear definition of a ‘practice’ before the RCVS proceeds with mandatory practice regulation, and a phased approach that enables a culture shift. We also call for a whistle-blowing process for employees to raise concerns anonymously (Rec 3.1)
- Rejection of proposals for the RCVS to have powers of entry, and instead we propose a system of short-notice interim inspections (Rec 3.2)
- Support for the principle of modernising the disciplinary process to focus on remedial action (Fitness to practise section), including support for interim orders to be used in a measured, consistent, and evidence-based way (Rec 4.3) and the introduction of a wider range of sanctions in line with a less punitive and more curative approach (Rec 4.5)
- Rejection of proposals for limited/restricted licensure for UK graduates with disabilities, as it may result in a two-tier system. Instead, we propose that vet schools and the RCVS make reasonable adjustments under the Equalities Act to enable students with disabilities to take exams and demonstrate day one competences (Rec 5.1)
- Cautious support for the principle of revalidation, subject to a clear articulation of the purpose and consultation on the details. We support the principle that veterinary professionals be required to demonstrate continued professional competence (Rec 5.2)
- A call for the process of setting the renewal fee to be transparent (Rec 8.2)
Commenting, BVA President James Russell said:
“This enormous piece of work to modernise our regulatory systems flows from the Vet Futures project and we’re pleased to be able to feed in our members’ views and concerns to the process.
“At the heart of our joint response with BVNA is a call for the right level of regulation that is proportionate to the level of risk. We embrace change and progress, but it must be evidence-based and delivered with a culture shift towards increased transparency and accountability of the RCVS as our regulator.”
Jo Oakden, BVNA President, said:
“The regulation of veterinary nursing has changed a lot in recent years and continues to evolve so we welcome this detailed consideration into the further enhancement and development of our profession.
“We’re delighted to see the RCVS re-stating its commitment to protecting the veterinary nurse title and this should be a priority in the coming months; it is something we at the BVNA are very keen to drive forward.
“As we’ve set out in this joint response with BVA, it’s essential that any changes to regulation and disciplinary systems have the confidence of veterinary professionals.”
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