BVA and BVNA issue joint response to the RCVS Legislative Reform Consultation.
The BVA and the BVNA have called for proportionate regulation in a major review of veterinary legislation.
In a joint response to the RCVS Legislative Reform Consultation, BVA and BNVA support the RCVS commitment ‘to progressing as a modern, fit-for-purpose regulator’ but stress the need for a ‘holistic approach and careful consideration of the chronology of changes’.
They also note that the principles of accountability 'must underpin any transition'.
The response, formed through various working groups, considered the recommendations of the RCVS Legislation Working Party report, together with several interim proposals that do not require legislative change, such as changing the standard of proof for disciplinary cases.
In their recommendations, BVA and BVNA suggest a halt to plans to change the standard of proof from criminal to civil in isolation. Instead, they stress that the change should only be considered after a package of measures has been implemented 'to foster a curative rather than punitive system'.
Other key recommendations of the BVA/BVNA response are:
- support for the regulation of some groups of evidence-led allied professions via the RCVS, but with safeguards to protect the reputation of the veterinary professions (Rec 1.1)
- support for separating employment and delegation to RVNs, but only within the context of the vet-led team (Rec 1.3)
- strong support for the protection of the veterinary nurse title (Rec 1.4)
- a call for the development of a framework for enhancing the RVN role rather than focusing on specific tasks, such as cat castrations (Rec 2.2)
- a call for a clear definition of a ‘practice’ before the RCVS proceeds with mandatory practice regulation, and a phased approach that enables a culture shift. We also call for a whistle-blowing process for employees to raise concerns anonymously (Rec 3.1)
- rejection of proposals for the RCVS to have powers of entry, and instead, we propose a system of short-notice interim inspections (Rec 3.2)
- support for the principle of modernising the disciplinary process to focus on remedial action (Fitness to practise section), including support for interim orders to be used in a measured, consistent, and evidence-based way (Rec 4.3) and the introduction of a wider range of sanctions in line with a less punitive and more curative approach (Rec 4.5)
- rejection of proposals for limited/restricted licensure for UK graduates with disabilities, as it may result in a two-tier system. Instead, we propose that vet schools and the RCVS make reasonable adjustments under the Equalities Act to enable students with disabilities to take exams and demonstrate day one competencies (Rec 5.1)
- cautious support for the principle of revalidation, subject to a clear articulation of the purpose and consultation on the details. We support the principle that veterinary professionals be required to demonstrate continued professional competence (Rec 5.2)
- a call for the process of setting the renewal fee to be transparent (Rec 8.2).
BVA president James Russell said: “At the heart of our joint response with BVNA is a call for the right level of regulation that is proportionate to the level of risk. We embrace change and progress, but it must be evidence-based and delivered with a culture shift towards increased transparency and accountability of the RCVS as our regulator.”
BVNA president, Jo Oakden, said: “We’re delighted to see the RCVS re-stating its commitment to protecting the veterinary nurse title and this should be a priority in the coming months; it is something we at the BVNA are very keen to drive forward.
“As we’ve set out in this joint response with BVA, it’s essential that any changes to regulation and disciplinary systems have the confidence of veterinary professionals.”
The RCVS legislative reform consultation closed on Friday (23 April). To view the full report visit rcvs.org.uk