Policy and Standards Department
The Health and Care Professions Council
Park House
184 Kennington Park Road
London SE11 4BU
5th December 2016
Dear Sir
Introduction
The College of Occupational Therapists is pleased to respond to the latest consultation on the
HCPC Standards of Education and Training, following a period of consultation with occupational
therapists within our organisation and externally with education partners in occupational therapy.
About the College
The College of Occupational Therapists is the professional body for occupational therapists and
represents over 30,000 occupational therapists, support workers and students from across the
United Kingdom. Occupational therapists work in the NHS, Local Authority social care services,
housing, schools, prisons, voluntary and independent sectors, and vocational and employment
rehabilitation services. Occupational therapists are regulated by the Health Care Professions
Council, and work with people of all ages with a wide range of occupational problems resulting from
physical, mental, social or developmental difficulties.
The philosophy of occupational therapy is founded on the concept that occupation is essential to
human existence and good health and wellbeing. Occupation includes all the things that people do
or participate in e.g. caring for themselves and others, working, learning, playing and interacting with
others. Being deprived of or having limited access to occupation can affect physical and
psychological health.
Consultation Response
The consultation questions will be addressed, and further feedback from our internal and external
stakeholders will be submitted via Table 1.
Detailed points related to the comments will be presented in table format, see Table 1.
Q1. Do you think the draft revised SETs are at the threshold level necessary to ensure that all
learners are able to practise their profession safely and effectively by completion of a HCPCapproved programme?
The draft revised SETs appear to have been strengthened to provide a more clear and robust
framework for educators to promote to learners. In particular, it is reassuring to note that many of
the new standards have been put in place to reflect recent education reforms in England, although
these standards will be of benefit to all four UK countries. The outcomes of the Francis Report and
other similar accounts of evidence of malpractice in healthcare settings also appear to have been
taken into consideration and addressed in this version of the standards.
For further detailed information, see the table below in Table. 1
Q2. Do you think the draft revised SETs and supporting guidance are applicable across all
HCPC approved pre-registration programmes?
As far as it is possible to say, yes.
Q3. Do you think there are any additional standards or guidance needed?
Yes. See point relating to Standard 3.16 in Table. 1.
Q4. Do you think there are any standards or guidance which should be amended or
removed?
As for Q.3, see Table. 1.
Q5. Do you have any comments about the language used in the SETs or supporting
guidance?
The College is encouraged to note the adjustment in use of language to strengthen messages within
the standards and also to address current cultures across Health and Social Care settings.
Q6. Do you have any other comments on the SETs or supporting guidance?
It is important to ensure that all concerned parties are aware of the SETs, their purpose and the
rigour they create not only to protect the learner but the service user or patient.
Table 1.
HCPC SET
2.6
There must be an appropriate and
effective process for assessing
applicants’ prior learning and
experience
3.4
This programme must be
sustainable and fit for purpose
3.6
3.8
3.9
3.14
COT comment
Also reflected in COT L&D Standard 3
COT ask that the Programme Lead must be an
‘occupational therapist of good standing’
Reflected in COT L&D Standard 1
New standard
COT is encouraged to see the addition of this
There must be an effective process
standard as it reinforces the requirement to
in place to ensure the availability and proactively build on existing structures to meet the
capacity of practice based learning
needs of learners in practice education settings.
for all learners
This may have other advantages, for example it
could help ensure that time for practice based
education is protected/acknowledged
New Standard
Learners should be elected representatives and
Learners must be involved in the
not selected by the programme team. This
design, delivery and review of the
standard is new to HCPC and WFOT, but not to
programme
COT.
Also reflected in COT L&D Standard 4
There must be an adequate number
of appropriately qualified and
Also reflected in COT L&D Standard 1
experienced staff in place to deliver
an effective programme
The programme must implement and HCPC standard is more detailed than COT and
3.15
3.16
3.17
4.2
4.4
5.6
6.6
monitor equality and diversity
policies in relation to learners
There must be a thorough and
effective process in place for
receiving and responding to learner
complaints
There must be thorough and
effective processes in place for
ensuring the ongoing suitability of
learners’ conduct, character and
health.
New Standard
There must be an effective process
in place to support and enable
learners to raise concerns about the
safety and wellbeing of service users
The learning outcomes must ensure
that learners understand and are
able to meet the expectations of
professional behaviour, including the
standards of conduct, performance
and ethics
The curriculum must remain relevant
to current practice.
Practice educators must have
relevant knowledge, skills and
experience to support safe and
effective learning and, unless other
arrangements are agreed, must be
on the relevant part of the Register
There must be an effective process
in place for learners to make
academic appeals
may be something for COT to consider going
forwards to next iteration of L&D Standards
Encouraged by this strengthened standard and
requirement to ensure that complaints are
followed through
COT feel strongly that this procedure needs to be
robust
Particularly welcomed. This is currently
incorporated within COT Code of Conduct and
Ethics but is likely to receive a more prominent
place in the next iteration of COT L&D Standards
COT is encouraged by the enhancement of this
standard.
This is particularly welcomed, especially the point
relating to demonstrating how the curriculum
facilitates developments in the professions’
research and advances in technology.
It is important that there is an element of
supervision delivered by a qualified occupational
therapist and from COT’s perspective, this needs
to be made clear within the standard.
This is very welcomed by COT as we feel a
responsibility to ensure effective and fair
treatment of student issues, but it is important to
ensure that the process is clear
References
COT (2014): College of Occupational Therapists learning and development standards for preregistration education. Available at: http://www.cot.co.uk/publication/z-listing/college-occupationaltherapists-learning-and-development-standards-pre-regis-0 accessed on 5/12/16
Further information on any aspect of this response can be gained by contacting
[email protected]
Yours sincerely,
Maureen Shiells
Education Manager | Pre-registration and Policy
The College of Occupational Therapists