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6.0 Responsibility for, and effectiveness of, healthcare standards (recommendations 19 – 59)

6.1 As noted above, regulation is primarily a matter for governments and, having examined recommendations 19 - 59, we re-iterate this view. We set out in this response those things we have done, are doing and will continue to do to play our part in the delivery of effective, high standards of healthcare. In this regard, we draw particular attention to the revision of our Code of Professional Conduct,2 our work to promote the accreditation of imaging services to the ISAS Standard (which includes direct observation of practice and direct interaction with patients, those accompanying patients, and staff as part of the accreditation and periodic re-accreditation process). We also draw particular attention to our intention to develop a similar process to ISAS for radiotherapy services, and our work to become accredited by the National Institute for Health and Care Excellence (NICE) relative to our professional guidance. 

6.2 In our view, the regulatory framework for the delivery of healthcare services should support the adoption of high standards of care, be focussed on care outcomes and encourage openness about, and reporting of, errors and breaches so that organisations adopt a cycle of continuous learning that works to keep patients safe and properly cared for. Where it is clear that a service is incapable of meeting fundamental standards, we agree there should be strong measures available to deal effectively with system failure and to hold to account those individuals responsible for leading those failing services. 

6.3 We agree that NICE has a very important part to play in establishing standards, measures and tools for the delivery of safe, high quality healthcare. We particularly welcome the call for NICE to produce evidence-based tools for establishing the likely requirements for staff numbers and skill mix in services. We believe such tools will be useful to prevent reductions in staff and unsafe skill mix on the basis of cost and affordability. In our experience, saving costs is the main driver for cutting staffing levels, often without regard to what is the safe staffing level and complement.

6.4 The work of NICE is important but we believe it could improve its work by drawing on a much wider range of expertise than it normally does and it must become more welcoming and inclusive of the expertise of the allied health professions, including the radiography profession.

6.5 Similarly, we agree that board members should include representatives of the professions. But we believe that board membership should be on competence and capability rather than because an individual is from a particular profession. In our view, reserved seats for named professions are not appropriate.

6.6 Members of our profession are more than capable of contributing to the work of NICE and of taking up board level positions. However, they need the support of their employers and, sadly, this is often absent. This is a matter whereby UK Health Departments and NHS England could demonstrate leadership by providing clear policy and guidance and we call upon them to do so.

  • As a professional and representative body, we have a compelling duty to report bodies and individuals that we consider to be failing to the relevant regulator(s). We are clear that we have done, and will continue to do, this.
  • We welcome the recommendation (23) that NICE’s work should include measures of suitability and competence of staff, the culture of organisations, and evidence-based tools to establish necessary staff numbers and skill mix. We will work with NICE on these matters when appropriate.
  • We call on the UK Health Departments to provide NHS commissioning and provider organisations with clear policy and guidance on supporting NHS employees to contribute to the work of NICE, Health Boards, and similar organisations.


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