The Health and Care Professions Council is consulting on increasing its annual registration fee from £80 to £90. This affects all 16 professions regulated by HCPC.
This is an increase of 12.5% and comes hot on the heels of the 5% fee increase that took effect in April 2014. It comes during a period when registrants have suffered five years of real terms pay cuts.
Download the consultation here:
This briefing summarises the consultation and invites activists to give their views so we can formulate a UNISON response.
Why this increase now?
When HCPC consulted on the 5% fee increase for April 2014, it said it would not review fees for another two years. The reason given for this u-turn is the outgoing government’s decision to cease funding for the Professional Standards Authority (PSA). Instead a levy on the individual regulators is being introduced.
Unsurprisingly the regulators are passing the cost straight on to registrants.
The NMC has already raised its fees from £100 to £120 effective from February 2015, with no guarantees that there will not be more increases next year.
Why a 12.5% increase?
The government claims that the PSA levy amounts to £3 per year per registrant. And the HCPC’s own paper states that its PSA levy will amount to around £1m per year. Divided by its approximately 330,000 registrants that comes to £3 per registrant.
So why is HCPC increasing the annual registration fee by £10?
The answer appears to lie in paras 3.14 to 3.26 of the consultation document under the heading ‘Other reasons for the proposed increase’. It explains that “The remainder of the increase…is necessary in order to ensure that we continue to be able to perform as an effective and efficient regulator over the medium to long term.”
The items listed under ‘Other reasons’ are:
- Investment in IT systems
- Introducing dedicated quality control
- Rising costs of fitness to practice and the need to invest in more space to hold hearings – the number of new cases is increasing faster than the number of new registrants
This raises some major questions about why HCPC should be slipping what appears to be an extra £7 fee increase under cover of the PSA levy.
This does not appear to be very transparent so we have asked HCPC to provide further information on how the £10 proposed increase breaks down between the PSA levy and ‘Other reasons’.
Why the short consultation period?
The HCPC says that it is to ensure changes can be made to coincide with the PSA levy coming into effect. However, the consultation period is for less than six weeks and includes the Easter and early May bank holidays. It also coincides with the dissolution of Parliament and the election campaign. This makes it more difficult for registrants to have their say and for there to be any democratic scrutiny of HCPC’s actions. One of the last debates in this Parliament was on the NMC increases and was well-attended, including by UNISON MPs – see Hansard report.
Is it the same for everyone?
- In relation to part-time staff HCPC has repeated its position that it will not offer a discount for part-time staff because its costs for them are the same.
- Renewal dates for the professions differ. This means some groups would be hit by a fee increase earlier than others. The table below shows that OTs would be the first group to have to pay the new higher fee, whereas some other professions will only start paying the increase nearly two years later.
|Profession||Date of renewal/date higher fee kicks in|
|Occupational therapists||August 2015|
|Biomedical scientists||September 2015|
|Arts therapists||March 2016|
|Chiropodists / Podiatrists||May 2016|
|Hearing aid dispensers||May 2016|
|Operating department practitioners||September 2016|
|Social workers in England||September 2016|
|Practitioner psychologists||March 2017|
|Clinical scientists||July 2017|
|Speech and language therapists||July 2017|
- In addition some groups including OTs will not have been hit yet by the £4 a year increase that took effect from April 2014, as they last renewed before then. They will therefore be facing a total increase of £14 when they come to renew.
The consultation proposes 12.5% increases to all other HCPC fees apart from the restoration fee. This is the fee payable for someone applying to come back on the register after having been struck off. There is a proposed 193% increase to this fee from £200 to £585!
The HCPC does propose to allow direct debit payers to pay in a greater number of instalments (something UNISON requested) perhaps monthly or quarterly. Currently instalments are six-monthly.
- Firstly the consultation period is unacceptably short and appears designed to slip the increases through with minimal scrutiny
- In common with our nursing sector colleagues we oppose the PSA levy and believe that if an oversight body is considered necessary for public protection it should be funded by the government and the devolved administrations, not levied on hard-pressed registrants.
- We will call on the next government to first implement the Law Commission recommendations and introduce the Commission’s draft Bill before allowing any of the regulators to implement fee increases. This Bill has cross-party support and sets out to streamline the regulators and reform their fitness to practice procedures – potentially delivering cost savings.
- A 12.5% increase in fees at a time when registrants’ pay is worth 10% less than in 2010 is wholly unacceptable. This is effectively a tax on practising unilaterally raised with little public scrutiny or debate.
- The HCPC should be much more transparent about how the proposed £10 increase has been arrived at, and how much of it is actually down to the PSA levy
- The HCPC should develop an action plan to investigate why the number of cases received has increased so much and how much of this is accounted for by inappropriate referrals. It should also review the necessity for investigations which do not result in a hearing.
- Before using registrants’ money to acquire more space to hold more hearings, the HCPC should do everything in its power to reduce the number of hearings where these can be avoided by better investigation at referral stage.