The new standards for occupational health in the UK - FeatureArticleLucy Kenyon investigates how the new accreditation sys...
3. To be administered by an independent body. 4. The accreditation should encourage organisational development.Written and...
nursing professionals and representatives of their professional bodies. OH providers offeringnurse-led services should con...
The Department of Health business probity audit processes include:  • the adequacy of financial systems  • the appropriate...
OH services should operate as exemplary employers and therefore have the strategies andinformation to assist their clients...
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Health And Safety Expert The New Standards For Occupational Health In The Uk Feature Article


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Article explaining the impact of the implementation of the new FOM regulations

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Health And Safety Expert The New Standards For Occupational Health In The Uk Feature Article

  1. 1. The new standards for occupational health in the UK - FeatureArticleLucy Kenyon investigates how the new accreditation system for occupational healthstandards in the UK could work, looks at potential pitfalls and what occupationalhealth service providers need to do now.IntroductionIn 2008, the Select Committee on Work and Pensions published a Third Special Report, whichidentified “potential for the Health and Safety Executive (HSE) to build on its StressManagement Standards as a tool to demonstrate what a ‘good’, healthy workplace should be,including what constitutes a good occupational health structure within an organisation”.Occupational health (OH) providers were previously encouraged to “embrace the opportunitiesand mutual benefit of self-governance and regulation of quality within both occupational healthand well-being services”, in the expectation that this would raise awareness of the professionalOH services available to employers and deliver opportunities to promote our profile within theresearch community.The new performance standards published by the Faculty of Occupational Medicine (FOM) giveOH providers the opportunity to assess and benchmark themselves and join an accreditationscheme equivalent to a quality mark. The standards set six categories. 1. Business probity. 2. Information governance. 3. People. 4. Facilities and equipment. 5. Relationships with purchasers. 6. Relationships with workers.Having issued the standards, the FOM is now developing an accreditation system to be pilotedlater in 2010 and operational in early 2011. In order to explore what accreditation might looklike, it is useful to take a look at existing professional accreditation systems in detail.The World Health Organization advocates for sustainable external quality assessmentprogrammes and it is necessary to: • identify national training and resource needs • allow the development of national and global advocacy tools for excellence • identify deficiencies in procedures, practices and materials • encourage the use of standardised procedures, practices and materials.A review of accreditation systems for health service delivery recommended that a robustprocess should constitute “an external review of quality” with four principal components. 1. To be based on written and published standards. 2. To be peer reviewed.
  2. 2. 3. To be administered by an independent body. 4. The accreditation should encourage organisational development.Written and published standardsThe FOM has now published standards for core clinical occupational health services. These donot apply to non-clinical services, eg occupational hygiene and ergonomics. OH services seekingaccreditation will need to ensure that professional advisory services are supported by suitablyqualified or registered individuals.The standards represent minimum standards of professional activities. No OH service will beaccredited if it fails to meet all applicable statutory requirements.Pre-qualification questionnaireOH services seeking accreditation will have to attest to meeting eligibility criteria foraccreditation, providing true and contemporaneous and not misleading information, complyingwith all applicable laws and regulations and having appropriate insurances. The attestation willhave to be signed or co-signed by at least one registered health professional from the OHservice.It is not clear from the publication whether health professionals have been petitioned about therequirement to sign the attestation, nor whether they believe they have the necessary skills,knowledge or competence to attest about, eg business probity.Many smaller providers seeking accreditation will lack the resources to carry out a review ofthird parties carrying out assessments at small satellite or remote locations of customers andwill shy away from recommending fellow providers.Customer satisfaction surveysOH services seeking accreditation or re-accreditation will have to provide a list of customers andkey contacts from which a sample will be approached to complete and return a customersatisfaction survey answering pre-determined questions. Small service providers which havejust one client should engage with the client to ensure that there is mutual understanding of thesystems and processes required for accreditation.Web-based assessmentThis will allow evidence to be submitted online to determine the readiness of the OH service foran on-site assessment visit.On-site assessment visitAn external audit will be undertaken by a visit to the OH service. It is not clear what this willlook like where the service is delivered on-site for the client with minimal records held at theregistered address. Small service providers which involve themselves early in the developmentof accreditation will have the opportunity to ensure that the external audit assessmentembraces the full range of providers in the marketplace.Self assessmentOH services seeking accreditation or re-accreditation will have to undertake self-assessments inyears when an external audit is not performed. Professional OH staff will be familiar with selfassessment and portfolio evidence, and businesses employing OH professionals should call onthese skills when considering applying for accreditation. This could operate in a similar way tothe online self assessment operated by schools.Review by professional peersThe stakeholder group involved in the development of the standards includes a number of
  3. 3. nursing professionals and representatives of their professional bodies. OH providers offeringnurse-led services should consult their representatives about how external accreditation will beadministered by their peers.Encouraging organisational developmentThe standards clearly state that accreditation is not an end point. It is intended to drivecontinuous improvement, allowing OH services to self-assess their services and performanceagainst standards, identify improvement areas and take remedial actions.Other accreditation services have shown that organisations that use them can spot potentialweaknesses in their programmes or services and work proactively to prevent these becoming aproblem.Impact assessmentLord Darzi’s 2008 report, High Quality Care for All: NHS Next Stage Review and a Google searchfor accreditation systems monitoring services similar to OH, generated a limited number ofresults. One such service is the International Accreditation Society, which aims to provideassurances that agreed standards for training and assessment are being met through anindependent monitoring and review service for those wishing to develop a world classmanagement style.In its response to Dame Carol Black’s report, the Institution of Engineering and Technologyrefers to a shortage of OH professionals. This remains unresolved today, and it is hard to seehow an accreditation system, which appears heavy on paper evidence, is going to encouragemore practitioners into the field. The report also talks about the barriers facing employers whentrying to implement complex and expensive solutions. In the longer term, accreditation willneed to encompass the softer evidence for “value for money” and ease of implementation, asthis is likely to be a key driver for employers.On face value, the process appears to require evidence of process rather than evidence ofrobust practice. An example would be the recruitment of professionals. Is a standard interviewquestionnaire as good as notes from an interview recording the answers given by an exceptionalcandidate? But of course, how many candidates would want the interview notes published? Willthis improve or hinder the number of people coming into the profession?Quality systems are great when it comes to ensuring that widgets are all sized within tolerances— none of us want to fly on a plane whose engine parts are out of balance — or that there is aminimum rather than average number of screws in a self-build wardrobe. But how realistic is itto focus resources on a system rather than professional opinion and judgment? Who is theaccreditation there to help? The companies asking for ethical and professional advice? Or theinsurance companies seeking to challenge employer liability claims?Business probityThe author believes that, managed in the right way, the new accreditation has the potential tochange the way OH services are marketed and sold, and to level the playing field between largeestablished providers with the resources to invest in their products and new entrants to themarket. This is very important where there is a shortage of OH services and competent OHprofessionals. This could encourage OH professionals, who have transferred their skillselsewhere in the professional services market, back into the field of OH.The most important factor of the new standards is probably the opportunity to demonstrate theintegrity with which OH services are offered and developed. Many larger organisations now offeroff-the-shelf packages, marketed and sold by sales professionals rather than OH professionals.The risk of this strategy is that the services sold to an organisation do not match their needs interms of outcome. Employers need to be sure that their needs have been understood and thatthe product is going to add value. An example of this is a sickness absence service thatoperates on the basis of a single assessment with the individual. If the individual’s recovery isatypical or a return to work is not straightforward, the employer does not have access to anyfollow up unless it buys another single assessment or a different product.
  4. 4. The Department of Health business probity audit processes include: • the adequacy of financial systems • the appropriateness of arrangements for the prevention and detection of loss arising from fraud or corruption • the adequacy of arrangements for establishing the legality of proposed actions • the accuracy of the annual accounts.OH business probity will be assessed via a customer questionnaire. This is an area where NHSplus services may be at an advantage. Small and independent sector providers should start toconsider and document their corporate and social responsibility policies and procedures and howthis influences their service offering and pricing strategy.Information governanceOver recent years, the Information Commissioner’s Office has developed strict codes around themanagement of information. This is supported by the guidance provided by the professionalbodies that govern medicine and nursing. Providers will need to develop a policy statement andprocedure to demonstrate how they comply with the various codes of practice, to support theattestation and for submission to the web-based assessment.The provision of meaningful data from confidential services is an ongoing issue for OHproviders. There continues to be a gap between the reports required by employers and thosepossible from data management systems. Review reports generated through the newaccreditation service should help providers to identify and acknowledge the weaknesses in theirdata management systems, and understand the need to revisit the recording and reporting ofqualitative information.PeopleCompetence has been a hot topic for some time now, especially with the advent of newprofessional roles allied to OH, eg case managers and OH technicians. There are some legacyissues surrounding the competence of both registered and unregistered professionals deliveringOH services that will need to be addressed. There is an opportunity here for accreditation toinfluence the professional registration bodies.Facilities and equipmentThe calibration of equipment is essential to the safe delivery of, in particular, health surveillanceservices. However, this can be mitigated by the use of appropriate validated questionnaire toolswith onward referral for specialist assessment by symptom profile. OH professionals are oftenrequired to deliver professional services on site in locations that do not allow for privacy anddiscourage full disclosure of symptoms by workers.When accreditation has become established, there is another opportunity here for accreditationto influence employers through their professional or industrial bodies to take these issues moreseriously.Relationships with purchasersThis links back to the principles discussed in business probity. Services offered from afoundation of ethical principles are more likely to be credible and compelling for employers. OHproviders should be able to use the evidence portfolio for this standard as a toolkit to planservices with a new customer.Relationships with workersThis is probably the most complex area of OH practice. This is especially true where employersare introducing OH for the first time and have not consulted sufficiently with staff.
  5. 5. OH services should operate as exemplary employers and therefore have the strategies andinformation to assist their clients where relationships with workers become a problem. Clearly,there are some very sensitive issues here and the FOM stakeholder groups should be able to actas advocates on this issue.DiscussionVoluntary accreditation systems are considered to be more effective than mandatoryprogrammes, as they are seen as an acknowledgement of reality, and tend to set sights higherthan the minimum. They are most effective when they combine both evaluation and supportiveconsultation, which means that the accrediting reviewer must hold professional credibility toadvise and recommend change. The FOM of the Royal College of Physicians is an authoritativebody for consultation in matters of education and public interest concerning occupationalmedicine.Since the early 1980s, the Association of MBAs (AMBA) has developed an accreditation service,which it believes gives business schools international credibility and status. It helps students toselect a meticulously tested programme and employers to recruit staff who have succeeded inthat programme. The AMBA accreditation process is designed to help business schools spotpotential shortcomings in their programmes through a consultative report following theassessment, which outlines recommendations for improving provision in the future.When FOM accreditation is implemented, it should include as standard a recommendationsreport following each self and on-site assessment. It should also provide a helpline to supportboth employers and OH providers seeking accreditation and trying to overcome issueshighlighted by the process.ConclusionEmployers will need advice and help to ensure that their OH services are appropriate, suitableand competent. What is not certain is whether the current standards address employers’ keyconcerns when procuring OH services. This is particularly true with respect to the standards forbusiness probity and people.OH services wishing to prepare for accreditation need to start to collect and collate evidence ina portfolio. Providers who do use valued and competent but unregistered professionals will needto ensure that their performance management frameworks are included in this portfolio. Thismay create some unease about sharing confidential and commercially sensitive information in ahighly competitive market.As accreditation is not becoming available till 2011, employers interested in achievingaccreditation should engage with the FOM to participate in any pilot or trial exercises. This willoffer the opportunity to influence the accreditation process to make it more user-friendly andalso enable them to achieve accreditation at the earliest opportunity.Further information • Occupational Health Service: Standards for Accreditation, FOM, January 2010Last updated on 19/05/2010© Wolters Kluwer (UK) Limited. This article was correct at the date of publication. It is intended asan aid and cannot be expected to replace specific professional advice and judgment. No liability forerrors or omissions will be accepted. It is the responsibility of those using the information toensure it complies with the law at the time of use and that it is used in line with relevant rules andregulations governing the subject matter in question.