Read again: Recruiting and managing primary care first contact practitioners

What are the responsibilities of providers when recruiting and managing staff deployed in first contact practitioner roles (FCPs) in primary care settings? Find out below

CREDIT: This is an edited version of an article that originally appeared on CQC

First contact practitioner roles in primary care include:

• Paramedics
• First contact physiotherapists
• Dietitians
• Podiatrists
• Occupational therapists

Certain positions will receive funding via NHS England and NHS Improvement’s Additional Roles Reimbursement Scheme. This scheme encompasses criteria for recruitment, training, and supervision. It’s advisable to review a condensed overview of these supplementary prerequisites in conjunction with this document.

This myth-debunking information pertains to personnel contracted under the reimbursement scheme. This includes roles like social prescribing link workers, physician associates, and other First Contact Practitioners (FCPs) employed within primary care environments.

Background

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 the option to be reimbursed at a lower level in a rotational scheme. These paramedics are not first contact practitioners.

Regulatory requirements

First-contact practitioner roles within primary care have the potential to enhance patient care by ensuring optimal patient-provider interactions. Nevertheless, some staff in these positions might be new to the primary care setting, which could be unfamiliar to them.

The integration of first-contact practitioners into Primary Care Networks (PCNs) signifies a significant transformation for general practice providers. While these providers may not directly employ some of the staff filling these roles, these staff members are responsible for delivering regulated services on their behalf.

All General Practitioners (GPs) who provide regulated services must register with the Care Quality Commission (CQC) as per the Health and Social Care Act. During the registration process, providers must demonstrate how they intend to comply with the regulations.

The Health and Social Care Act 2008 (Regulated Activities) 2014 Regulations delineate the responsibilities of providers. Our guidance for providers on regulatory compliance clarifies that providers are answerable for the individuals they ’employ.’

However, the term ’employed’ within the regulations encompasses more than just staff under a formal employment contract. It encompasses anyone working for the provider under their continuous guidance and supervision. The provider must ensure the ‘fitness’ of these individuals. Recruitment through another party may offer some assurance, but registered providers should not presume that all necessary checks have been conducted.

During an inspection, the CQC 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:

• Safe
• Effective
• Caring
• Responsive
• Well-led

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

The CQC will expect to see evidence that the provider has verified and is satisfied about safe recruitment practices. 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.

Governance systems

The CQC 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.

Suitably qualified, competent and experienced staff

The CQC expect appropriate recruitment checks, professional registration and supervision for all staff. This expectation is irrespective of who holds the employment contract.

Assessing staff skills, knowledge and experience

The CQC will use its 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
• Induction
• Policies and procedures
• Communication of alerts and guidance
• Clinical supervision
• Complaints and significant event arrangements.

The CQC will check how the provider has assured themselves that staff are capable for the role. It 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.