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Consultation analysis - draft standards for the foot health workforce - results
This section describes the results using the main themes as section headings. The sub-themes are embedded within the context of the results described under each section heading.
Implementation of the Standards
One of the intended benefits of the Standards is to bring unification and clarity to a diverse and often divided podiatry and foot health workforce. Some responses shared this vision.
“This is a great idea, decades too late but at least it’s happening now……”
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“I welcome these Standards being implemented and think that the opportunities that will be given to upgrade yourself are great”
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“I would like to thank all of those who helped create this document. It must have been a long and sometimes problematic process, so I just wanted to say that the end result and the foundation that it creates, is much appreciated”
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“It is long overdue! Thank you to the team who have got together and worked through this to come up with a list of Standards. I fully support it and I look forward to a more harmonious working relationship with FHPs as a result.”
Respondents representing the NHS sector broadly support the implementation of the Standards.
“We currently use this role [level 3] within our service as staff who work as Assistants play a valuable role in the care of the patients but also to allow the workload to be shared, so patients are seen in a timely manner and by the right clinician first time”
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“I see a need for foot health clinics to be run in our GP surgeries providing regular foot health checks for patients with diabetes. These clinics could be run by level 4 FHPs alleviating the pressure on nurses specialising in diabetes.”
Some responses recognise that implementing the Standards will be challenging.
“How do you progress from FCA level 3 to 4. If there are no FHP in the NHS currently- the FHP's- However this tends to be on the job training following completion of their course”
Other responses have questioned how the Standards would be implemented. At times, comments focussed on the negative consequences of introducing the Standards and reflected concern about the impact it may have on both individuals and the podiatry profession.
“It's all very well using FHPs in the NHS, but it does nothing to control those in the Private Sector who are non-regulated and unaccountable. Surely some kind of regulation for FHPs should come first”.
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“Flooding the NHS with non-regulated uncontrolled practitioners is not the answer.
This was tried years ago with 'Foot Care Assistants'. They got additional training from
the NHS (at taxpayers’ expense) then left after about a year to set up in the
private sector and described themselves as 'NHS trained'.
Some responses saw the Standards in a negative way and expressed concern that the podiatry profession would suffer because of having the Standards.
“I feel FHP [sic] is such a threat to podiatry. It feels like we are giving up on
podiatry and trying to focus on the more cost-effective FHP training”
Other comments focussed on how the Standards were going to be implemented and who was going to ensure that the Standards were being met?
“Which organising body will be involved in assessing the standard of training that
has been already given. Some FHPs have only done a minimal course that is
sometimes only a number of weeks’ long. Will they then have to be registered with
such body e.g., HCPC? And will they be audited and required to carry out a
minimum amount of CPD annually? “
Further responses call for regulation of the podiatry support workforce like that of the HCPC regulated workforce.
“Regulated education and sign off through regulated institutes”
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“The title ‘Foot Health Practitioner’ needs to be a protected title
with regulation such as the HCPC.”
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“A new single mandatory register for all newly qualified and currently
practicing FCA, FHP and AP should be implemented.”
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“All current FCA, FHP and AP should demonstrate they
are working within and to the new Standards”.
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“who is regulating this? Will they be required to reassess all
current patients who are unsuitable for their skill set?”
Some comments voiced anger and frustration at the idea of allowing non-regulated individuals working as part of the NHS workforce.
“do not support FHPs being employed in the NHS as it undermines our profession…”
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“do not believe FHPs should be employed in the NHS at all”
Conversely, some comments from foot health practitioners demonstrated frustration that there was not a stronger bond between the two main groups of responders – podiatrists and foot health practitioners.
“Trying to get help from podiatrists is impossible if you are an FHP”
Some commented that there is an unacceptable level of disrespect within the independent sector from the regulated sector toward the non-regulated sector.
“Verbally abused by podiatrists over the years”
Within the independent sector there was concern and anger about the scope of practice detailed within the Standards. Comments conveyed a desire to stop the non-regulated sector from practicing independently.
“They must not be allowed to work independently”
Some responses claim the current training of FHP’s is not sufficient to meet the Standards.
“Remove FHPs as their course does not allow for enough
clinical hours to allow safe practice on their own and they are not regulated …”
Finally, under the implementation theme there were comments around the implementation being NHS focussed and that the Standards should be rolled out across both the public and independent/private sector.
“My major concern is this appears to be all NHS based, not
taking into account the vast majority of Foot Health Practitioners
are private practitioners. I do not want to work for the NHS,
I want to be self-employed.”
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“Standards need to be implemented across both
NHS and independent sectors to ensure stability and
regulation of the foot health economy. This may require these
Standards to sit within legislation, to define the different roles.”
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“How is this going to be enforced in the private sector? Looking at section 3
"clinical domains", that is all well and good in an NHS setting where
roles can be controlled and patients are treated by the appropriate
clinician, but if you think these patient groups are safe to be treated
by these levels of training in the NHS, the same applies in
Private Practice, surely? So how will that be enforced?”
Training
Responses related to the second theme depicts a landscape where the diverse education and training of the non-regulated foot health workforce is leading to confusion and discrepancies around level and scope of practice, particularly within the independent sector.
“There should possibly be a clear way of understanding
any further courses the FCA's have attended furthering
their education. Specifically, what they have learned and to
what clinical standard in comparison to a podiatrist level of training.”
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“I feel all FHP should have a certain level of practical training &
mentorship during the first 6 months of registration. There
needs to be a properly operated body for registration of FHP
that is open & visible.”
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“I think the role title is not specific enough Assistant Practitioner (Podiatry)
is too long, too vague. In dentistry there are clear and specific titles
and roles that the public and practitioners understand easily.
This needs to be the same for podiatry.”
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“With such little training allowing this level of practitioner to undertake sharps
debridement even of the healthy patient Is wrong and puts patients
at risk. it is a skill that requires a higher level and longer training. I work
with excellent FHP who provide excellent nail care and foot health
education, but I do not feel their level of education provides
them with the competency required to sharps deride [sic].”
Notwithstanding, respondents could see that the Standards would be a useful addition for the NHS support workforce.
“Very useful piece of work around reviewing the clinical workforce.
Should help us to 'grow our own' staff in a much
more effective way to fill vacancies.”
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“I only have experience with training Foot care
assistants which is always a good professional session.
In NHS clinics they can have a very supportive role
both for the Clinician and Management.”
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“I have supported and mentored many FHPs trained
by private training schools. In my experience, I feel that
these new levels of foot health practitioners will enhance their skills.”
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… “encouragement should be given for an FCA to further their career
within the Podiatric profession. Pathways of training should
be given to the right candidate after a period of two years…”
Comments referred to the diversity in training that foot health practitioners receive in the independent sector. This has raised questions about this sector’s competence to practice in the way that the Standards outline at each level.
“As there are diverse training facilities with differing Standards – Practical
and theoretical skills should be at a required level before entry
into Level 3 Foot Care Assistant/ Foot Health Practitioner”
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“Perhaps NHS trusts can get involved with training foot health practitioners
so that would know everyone is working at the right level. This would
help to bridge the gap between NHS Podiatrists and Foot Health
Practitioners working in the private sector”
Some respondents raised concerns around the level of practical training provided by private companies.
“The training needs to be standardised. Being able to ‘qualify’ with absolutely
no hands-on experience from some training facilities is damaging to
everyone else that invested much more in time and money to be able to
train and qualify at a competent level.”
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“The fhp [sic] courses around vary greatly from many hours of
written and practical training to very cheap online courses
with little to no practical work.”
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“These FHP colleges are churning out ‘fully qualified’ practitioners on
weekly/fortnightly basis. Demeans the ‘gold standard’ Podiatry degree
practitioner who have studied for 3 years. There must be more
public awareness of the significant differences between the studies and
knowledge of Podiatrist and FHP.”
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“Minimum clinical hours before qualified needs to increase and they should
all be licensed by a registered body and have a podiatrist to oversee their work”
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“Longer practical training and the possibility of an Apprenticeship scheme
in which a student attends a clinic for a minimum of a 12-month period, the colleges
currently do not deliver enough hands-on training…...”
Responses also shared concern for the level of supervision available to the non-regulated sector working independently.
“Many Foot Health Practitioners are individual workers,
with limited resources and support. Whilst NHS Podiatrists
have many more opportunities for support and information….”
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“The skills a [sic] level 4 should be for those people who are working with/alongside
HCPC registered podiatrist. Independent use of these skills in
isolation/independent private practice should NOT be allowed.”
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“Community footcare should be at level 3 only if NOT
working under the direction of a HCPC podiatrist.”
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“Who is going to supervise them in a private setting?”
The roles associated with the proposed Standards has led to some respondents questioning whether further clarity over roles and job titles is required.
“This is a Confusing title for the General Public to
grasp and is deliberately confusing as Foot Health practitioners
advertise under the umbrella or associate themselves with the
term Chiropodist/Podiatrist, a protected title.”
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“I think the titles of the roles need to be looked at.
It's confusing for the public and in my opinion, doesn't
differentiate enough between the Standards required for the roles.”
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“These are not protected titles, [sic] the public will be misled.
The public expects, and would assume, that an NHS
practitioner is a regulated professional with standardised training.”
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“Public perception is that Podiatrists and Foot Health
Practitioners are already the same thing, so how will the
Standards ensure that the public know the difference and
know what Standards the practitioner they are seeing should stick to?”
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“I think there will be confusion over the title foot health
practitioner. This is not a protected title and is currently
used in private practice. There will be significant variation
in Standards between NHS FHPs and private practice
FHPs, and this will cause significant public confusion.”
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“Assistant Practitioners often have extremely honed skills in their field
of work and should be acknowledged for this e.g., orthotic technician.
Once again it is educating the general public the clear difference
between each discipline of FCA's podiatrists and assistant practitioners.
Each has their own skill set and valuable place within the system with
the correct education and training.”
Independent Sector
The final theme focusses on responses that share a view on the implications for the independent sector should the Standards become operational. There were mixed views on a range of topics. There were strong opinions on the lack of inclusion of the private sector within the remit of the proposed Standards.
“This has been geared to NHS, no thought to PP and how it will be affected.”
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“PP has been thrown under the bus with regulation of ALL FHPs ignored.”
Some responses support the Standards and convey how they could be used to assist private practitioners in the independent sector.
“It would be useful to use these Standards as a pathway for career development.
It would also be useful to use these Standards as a way to educate the public
about what the foot care workforce offers and what the different
qualifications mean. I appreciate that this work is for the NHS, but the
Standards could be used to assist private practitioners to know.”
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“In general, the Standards for this area of clinical practice are satisfactory
and I would not wish to amend these Standards. I would encourage
HEE to consider a mechanism by which the Standards would apply to all
Foot Health Practitioners working within both the NHS and Private Sector.”
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“More widely, will these standards be applied to all individuals working within
'foot health' but who are not Podiatrists and perhaps who are not working
in the NHS? Will the titles 'Foot Care Assistant', 'Foot Health Practitioner'
and 'Assistant Practitioner' be protected in law? By whom? Will these
titles be able to be used in the Independent Sector? Will they be
recognised by insurance companies?”
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Other responses suggest that the Standards should be linked to the education providers. Education providers meeting the Standards would bring a common understanding to the level of training provided to the non-regulated foot health sector by independent education providers.
“implementation should be with the training providers and having reached
the Standards should be registered and accredited. Training providers
who do not offer teaching to the required Standards must be
prevented from operating.”
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“Colleges, universities and further education establishments should
be encouraged to develop courses around the Standards and work
with local NHS boards to ensure there will be uptake of students once qualified.”
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“We need more podiatrists; I don’t like the idea of Foot Heath
practice being nearly equal to podiatrists. A degree is what
should be introduced, we work hard and still don’t get the
credit we deserve half the time.”
Some concerns were raised by responding FHP’s about how implementation of the Standards will affect them as individuals.
“Existing practitioners should be offered any upskilling needed to
at least meet minimum standards and operate at that level.”
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“Worried for us fhps [sic] who have trained and work
hard to provide a great service to our clients. Have we all got to be
retrained?? At our own expense to be allowed to continue to practice.”
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“All level three FHP should be grand-parented up to level 4 if they
have been practising for over three years. if [sic] not any extra
training needed to continue seeing the same client list and
doing the job they have already been doing should be free of charge
and they should be able to carry on working during this.”
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“How are the Standards going to apply to fhps [sic] currently out
there in private practice. How are they going to be regulated to
these Standards when their training and experience varies massively”?
Other respondents have commented on the need for strengthening support arrangements and co-working for the non-regulated foot health workforce working in independent practice.
“I would like to see more details on referral to senior colleagues.”
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“Be provided with opportunities to develop working relationships with
higher qualified practitioners.”
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“Impressive and a lot of work gone into them. May be challenging
for those working who have not kept up their skills in all the different
skill sets covered at their level. Would support/training be available
and who would provide/ fund it?”
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“It would be beneficial if independent FHP's have supervision
and referral pathways built into the Standards.”
Final Comments
Patient safety has always been central to the development of the Standards. Comments from responders echo the need to ensure that patients and the public should be front and central to the implementation of these Standards.
“I think it’s good to have a standardised qualification. The key to
the success of this project is to involve and engage the
end user- the general public.”
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“Once Standards have been implemented, there will be a
need to massively increase public awareness.”
In concluding this section, some final sentiments on what may assist implementation.