This mythbuster describes the responsibilities for providers when recruiting and managing staff deployed in first contact practitioner (FCP) roles in primary care settings. This includes:
- first contact physiotherapists
- occupational therapists
Some of these roles will be funded through NHS England and NHS Improvement’s Additional Roles Reimbursement Scheme, which includes requirements for recruiting, training and supervising. You should read a summary of these additional requirements alongside this document. This mythbuster applies both to staff employed using the reimbursement scheme and to other FCPs employed in primary care settings.
As part of the NHS Long Term Plan, primary care networks (PCNs) and GPs were encouraged to build a team of people with diverse skills to:
- support increased access for patients
- reduce pressures on existing staff
- improve the quality of care and services.
PCNs can receive funding for some of these roles from the Additional Roles Reimbursement Scheme. This can reimburse staff according to their skills, and capabilities and role, up to the maximum level of reimbursement, set out in the Network Contract Directed Enhanced Service (DES).
Allied health professionals (AHPs) can become first contact practitioners (FCPs) or advanced practitioners. Health Education England has developed a Roadmap for Practice for AHPs to show evidence of their capability for these roles. AHPs who have demonstrated these capabilities will be able to see and manage more clinically complex patients. They will also be able to work independently in primary care, within their scope of practice.
The Network Contract DES provides role descriptions for allied health professionals employed through the reimbursement scheme. Most AHPs will be working at a master’s level clinically. Paramedics will have an option to be reimbursed at a lower level in a rotational scheme. These paramedics are not first contact practitioners.
First contact practitioner roles in primary care can enhance patient care. They can help ensure the right person sees the patient at the right time. However, some of the staff deployed in these roles may be working in primary care for the first time and the setting may be unfamiliar.
The deployment of first contact practitioners through PCNs is a significant change for general practice providers. Providers will be accountable for staff who they may not employ directly, but who deliver regulated activity on their behalf.
All GPs responsible for delivering a regulated activity must register with CQC under the Health and Social Care Act. As part of the registration process, providers must show how they will meet the regulations.
The Health and Social Care Act 2008 (Regulated Activities) 2014 Regulations set out a provider’s responsibilities. Our guidance for providers on meeting the regulations explains that providers are responsible for the staff they 'employ.' However, the meaning of 'employed' in the regulations is wider than staff employed on an employment contract. It means anyone who works for the provider, under their ongoing direction and control. The provider needs to be assured about the ‘fitness’ of those persons. Recruitment by another party may provide some assurance. However, the registered provider should not assume these checks have been completed.
During an inspection, we will not review any regulated activity delivered by staff who are not employed or managed by a GP practice. This is because this activity is governed by a contract that the GP provider is not party to, and so is separately regulated.
Providers need to ensure that all the staff they manage have had the appropriate recruitment checks and are supervised. This is for all staff, irrespective of who holds the employment contract. This does not necessarily mean the provider must physically carry out or repeat all the processes. However, they do need to reasonably assure themselves that it has been done. For example, where a FCP is employed by a local NHS trust and provides services to a GP practice, it would be essential for the practice to ask for assurances. This could be a letter of confirmation, memorandum of understanding, or service level agreement from the trust. This needs to clarify the recruitment checks and responsibilities for day-to-day clinical supervision.
Primary care networks (as extensions of GP practices) determine how staff operate in general practice. GPs are required to be on the National Medical Performers List to provide general practice services. Other staff, such as nurses and allied health professionals, operate under the direct supervision of National Medical Performers.
Providers must ensure that staff are operating within the limits of their competency. They must also provide staff with appropriate supervision. The individual practice will allocate an appropriate senior member of the primary care team to provide day-to-day supervision of all clinical staff. Health Education England has published guidance for employers on workplace supervision for advanced clinical practice. The Health and Care Professions Council has also published guidance for AHPs on supervision standards.
First contact practitioners (FCPs) working in primary care are non-medical diagnostic clinicians. Training and education for FCPs is described in HEE’s Roadmap for Practice. Stage 1 of the roadmap should be completed with a signed off portfolio of evidence before employment in primary care. Stage 2 is completed when working in primary care. This should be within six months for those in full-time equivalent FCP roles or longer if the employer and commissioner agree.
CQC will expect to see evidence or assurance that staff recruited into FCP roles have completed stage 1 of the roadmap. We will also expect arrangements for completion of stage 2 of the roadmap.
When we inspect
We regulate at the level of the individual registered provider. In the case of primary care networks, this will be the GP practices listed as the Core Network Practices in the Network DES.
We apply the regulations of the Health and Social Care Act when we review if the practice is:
We will look for evidence that providers have systems in place to ensure that:
- staff are recruited appropriately
- staff are operating within the limits of their capability, scope of practice and competency
- they provide staff with appropriate information, support and supervision to enable them to carry out their role.
Fit and proper persons requirement
We will expect to see evidence that the provider has verified and is satisfied about safe recruitment practice. For example, asking the employer of a first contact practitioner for assurance and/or evidence that the necessary recruitment checks have been completed. This may include professional registration, Disclosure and Barring Service checks, references and qualifications.
This relates to Regulation 19: Fit and proper persons employed.
We will expect systems or processes to be in place to assess, monitor and mitigate the risks relating to the health, safety and welfare of patients. This expectation is irrespective of who holds the employment contract.
This relates to Regulation 17: Good governance.
Suitably qualified, competent and experienced staff
We expect appropriate recruitment checks, professional registration and supervision for all staff. This expectation is irrespective of who holds the employment contract.
This relates to Regulation 18: Staffing.
Assessing staff skills, knowledge and experience
We will use our key lines of enquiry to assess how providers ensure staff have the skills, knowledge and experience to deliver effective care.
This will include but is not limited to:
- safe recruitment
- job plans
- policies and procedures
- communication of alerts and guidance
- clinical supervision
- complaints and significant event arrangements.
We will check how the provider has assured themselves that staff are capable for the role. We will also check that the provider maintains this over time through ongoing supervision. This supervision may be carried out by any senior member of the team.
Frequently asked questions on the FCP/AP roadmaps (Health Education England)
Guidance on enabling the workforce (Health Education England)